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Results: 1-10 of 137

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

Sections 305 and 306 and tracking stock

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

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and

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

Quick peek discovery

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 1 2012

A U.S. Court of Federal Claims judge has rejected some privilege claims and directed the taxpayer to allow the government lawyers a “quick peek” at other documents the taxpayer does not want to turn over in discovery

Why we get spin-off rulings

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 20 2011

Former Parent owned Parent, which owned Controlled, which owned Sub 1, which owned Distributing

IRS may apply economic substance doctrine to securities lending transactions entered to avoid U.S. withholding tax

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 15 2013

In generic legal advice released in November 2012 (AM 2012-009), the Chief Counsel's Office, applying the economic substance doctrine, disregarded a

Section 305(b)(2) warrants

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 2 2012

LTR 201213011 rules that a domestic corporation can generate a section 301 distribution to its shareholder(s), possibly for the purpose of creating capital gain, possibly to allow use of an expiring capital loss of the shareholder

CERT regulation proposed

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 17 2012

Twenty three years after it was enacted in 1989, the Treasury issued proposed regulations interpreting section 172(h), the corporate equity reduction transaction (CERT) loss carryback disallowance rule dating from the heyday of the leveraged buyouts

F reorganizations and double dummies

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 1 2012

LTR 201222014 ruled that persons contributing property to a new corporation in exchange for stock can form a control group with other persons contributing the stock of another corporation (target), and therefore enjoy Section 351 nonrecognition treatment

Final regulations on disregarded entities involved in conduit arrangements

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 15 2011

On December 9, 2011, the IRS published final regulations that address the application of the conduit financing arrangements effected through disregarded entities