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Results: 1-10 of 134

Ignore constitutional issues? Horne v. Department of Agriculture, 2013 U.S. LEXIS 4357 (2013)

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

Administrative agencies, including the IRS, commonly decline to consider challenges based on the Constitution or otherwise asserting that the law is

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

Economic substance doctrine bill: unanswered questions

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 1 2009

The bill aims to resolve or inform two, and only two, uncertainties that Congress believes the courts encounter when applying what the bill calls the “economic substance doctrine” to federal income tax disputes

Circular flow and F reorganization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 3 2011

LTR 201050020 is one of a fairly large number of letter rulings issued recently on novel reincorporation patterns

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

Credit unions under attack

  • Alston & Bird LLP
  • -
  • USA
  • -
  • September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members

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

IRS’ schedule of uncertain tax positions raises concerns for preserving privilege

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

In response to a claimed need to allocate IRS resources to significant issues and improve audit efficiency, the IRS issued Announcement 2010-9 in January 2010, setting forth a new initiative that would require certain business taxpayers to disclose uncertain tax positions (UTP) on a new schedule that would be filed with their federal income tax returns

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

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