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Results: 1-10 of 135

Two Supreme Court tax decisions

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 1 2014

During the current term, the Supreme Court of the United States decided very few tax cases. Two of those seem quite limited in scope, until you delve

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

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

REIT real property regulation proposed

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 20 2014

Prop. Reg. Section 1.856-10 will define real property that will satisfy the income and asset requirements for REITs. It will replace Reg. Section 1

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

Supreme Court to review economic substance case

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

United States v. Gary Woods, 471 Fed. Appx. 320 (5th Cir. 2012), affirming per curiam, 794 F. Supp. 2d 714 (WD Tex. 2011), will be reviewed by the

Section 304 games

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 23 2013

Since the repeal of the collapsible corporation rules, section 304 has been the most confusing corporate tax section in the domestic context. Its

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