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Results: 1-10 of 132

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

Loss duplication regulations finalized

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

Nine years after enactment of Section 362(e)(2) and seven years after proposal of regulations, the Treasury issued final regulations, effective for

Better luck with economic substance doctrine John Hancock Life Insurance Co. v. Commissioner, 141 T.C. No. 1 (2013)

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

John Hancock Life Insurance lost a recent decision in the U.S. Tax Court ruling on a combination of LILO and SILO transactions that were supposed to

Federal tax advisory: Section 336(e) regulations issued

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

Treasury has exercised its authority under Section 336(e) to write regulations allowing certain sellers of stock to elect to treat certain sales and