We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-10 of 135

Two Supreme Court tax decisions

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 1 2014

During the current term, the Supreme Court of the United States decided very few tax cases. Two of those seem quite limited in scope, until you delve

Last Granite Trust ruling LTR 201419011

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 2 2014

We keep thinking we have seen the last letter ruling allowing a taxpayer to separate a subsidiary liquidation from a preliminary decontrolling stock

REIT real property regulation proposed

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 20 2014

Prop. Reg. Section 1.856-10 will define real property that will satisfy the income and asset requirements for REITs. It will replace Reg. Section 1

An unusual FD(?) reorganization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 1 2014

LTR 201406005 evidently blessed as an F or D reorganization the transfer by a subsidiary of all of its assets to its parent corporation, despite the

Important no-rule changes: Rev. Proc. 2014-3

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 3 2014

One of the most important bellwethers of what the IRS is thinking is the annual Revenue Procedure that announces the issues on which the IRS

Statutory interpretation still lives

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 1 2014

In early December, the Supreme Court of the United States ruled that the substantial valuation misstatement penalty could be determined in a TEFRA

Tax reform update

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 1 2013

Tax reform has been in the offing ever since the 2008 elections. It took a back seat to more pressing national problems for a few years, but calls

Internal spinoffs

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 25 2013

LTR 201347005 is a straightforward ruling on multiple internal spin-offs of Controlled holding one of the two businesses of a domestic group. The

Buying assets

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 1 2013

Once upon a time, it was common to sell and buy an ongoing business by deed, bill of sale and assignment and assumption of ongoing contracts. This

Section 304 games

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 23 2013

Since the repeal of the collapsible corporation rules, section 304 has been the most confusing corporate tax section in the domestic context. Its