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Results: 1-10 of 135

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

Foreign F reorganizations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 4 2011

U.S. Parent owned FS1, which owned DRE1, which owned DRE2. FS1 was domiciled in Country A but DRE1 and 2 were domiciled in Country B

Corporate letter rulings cut back

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 26 2013

Rev. Proc. 2013-32, issued on June 25, 2013, substantially restricts the scope of letter rulings that taxpayers can obtain from Chief Counsel

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

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

Earnings and profits reductions for 382 limited losses

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 10 2011

Section 382 limits the amount of deduction allowed for net operating losses and built in losses subject to section 382(h

Foreign patent commercialization

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

Corp. A licensed certain technology to G (called Agreement A) in the past

1504(a)(4) preferred

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 3 2012

Chief Counsel (Corporate) has advised the field that cumulative preferred stock on which the dividend mandatorily cumulated until redemption (and so section 305(c) applied) was section 1504(a)(4) preferred because it did not have a redemption premium (reasonable or unreasonable

The “conservative” tax majority on the Supreme Court

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

The two most recent decisions of the Supreme Court involving federal taxes illustrate how a conservative approach to statutory interpretation tends to prevail, but only with great effort, and changing constituencies

Last Granite Trust ruling LTR 201419011

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 2 2014

We keep thinking we have seen the last letter ruling allowing a taxpayer to separate a subsidiary liquidation from a preliminary decontrolling stock