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Results: 1-10 of 138

Convertible preferred equity certificates

  • Alston & Bird LLP
  • -
  • Luxembourg, USA
  • -
  • July 13 2011

Instruments may be treated as debt for foreign income tax purposes but as equity or U.S. tax purposes

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

CFC’S Subpart F earnings not qualified dividends

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

On December 7, 2011, The U.S. Tax Court ruled that inclusions in U.S. residents’ gross income that were required under the Subpart F provisions with respect to their controlled foreign corporation’s investments in U.S. property did not constitute qualified dividend income under Section 1(h) (11

Home Concrete decided: taxpayer wins

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 25 2012

On April 25, 2012 the Supreme Court ruled that the overstatement of the basis of property sold, resulting in a substantial understatement of gain, is not an omission from gross income, and so the three year and not the six year statute of limitations applied to the taxpayer’s assessment, meaning the assessment came too late

All-cash D regulation amended

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 1 2011

On November 18, 2011, the Treasury filed an amendment to the final regulations published in 2009 that address what is known as the all-cash D reorganization

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

Downstream D

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 7 2012

LTR 201214013 applies a 55 year old ruling to treat a subsidiary liquidation as a downstream D reorganization, thus preserving the basis in the liquidating subsidiary’s stock, which would not be the case if it had liquidated under section 332

North-South spinoffs

  • Alston & Bird LLP
  • -
  • USA
  • -
  • March 9 2012

A North-South spinoff is a section 355 distribution that is accompanied by a contribution of property from the shareholder to the Distributing corporation

IRS publishes proposed guidance on foreign government income under Section 892

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

The IRS has released proposed regulations relating to the taxation of the income of foreign governments from investments in the United States under Section 892

Lack of income tax deduction for payment of breakup fees

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 1 2010

As the country moves out of the recession, M&A activity is bound to heat up