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Results: 1-10 of 132

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

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

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

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

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

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

Closely held Section 305 issues

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

Section 305 is an antique weapon that mostly misfires

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

Federal tax advisory: Section 336(e) regulations issued

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

Treasury has exercised its authority under Section 336(e) to write regulations allowing certain sellers of stock to elect to treat certain sales and