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Results: 1-10 of 137

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

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

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

Cross chain 351?

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

LTR 201150021 is a surprising cross chain restructuring ruling that treats the transfer of the assets of one subsidiary of P to a subsidiary at the bottom of another chain of subsidiaries below P as a series of section 351 exchanges and a D reorganization at the bottom of the acquiring chain

Manchester United ruling?

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 22 2012

LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351

The worthless subsidiary problem

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 31 2013

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its

“Technical” revenue laws changes in North Carolina

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 5 2012

On June 21, 2012, the North Carolina General Assembly enacted its annual updates and so-called technical revisions of the revenue laws

Anschutz Company

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 13 2012

Just before New Year’s Eve 2011 the Tenth Circuit affirmed the Tax Court’s ruling against the taxpayer Anschutz Company in a case involving a variable prepaid forward contract

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