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Results: 1-10 of 138

D reorganization basis regulations finalized

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

In November the Treasury finalized a temporary and proposed regulation dealing with the basis of stock of the target corporation in a nondivisive D

Inversions and Notice 2014-52

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

The hottest topic in federal corporate taxation in many years is the corporate inversion. The Treasury Department recently released notice 2014-52

The attractive C corporation

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

In August a major energy company announced that the corporate managing partner would tender to buy out the publicly traded interests in its master

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