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REIT conversions

Alston & Bird LLP
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USA
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June 7 2013

LTR 201314002 has caused quite a buzz in the investment community. Stock pickers want to know how far the envelope can be pushed on the definition of

PPL and a wealth tax

Alston & Bird LLP
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USA
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June 3 2013

On May 20, 2013, the Supreme Court of the United States decided PPL Corporation and Subsidiaries v. Commissioner, 569 U.S. __ (2013). This was the

Convertible preferred equity certificates

Alston & Bird LLP
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Luxembourg, USA
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July 13 2011

Instruments may be treated as debt for foreign income tax purposes but as equity or U.S. tax purposes

Sections 305 and 306 and tracking stock

Alston & Bird LLP
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USA
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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

CFC’S Subpart F earnings not qualified dividends

Alston & Bird LLP
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USA
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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

Closing a prepaid forward with a short sale

Alston & Bird LLP
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USA
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October 24 2012

TAM 201214021 appears to reconsider an issue addressed in CCA 201104031, issued about a year earlier

Lack of income tax deduction for payment of breakup fees

Alston & Bird LLP
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USA
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July 1 2010

As the country moves out of the recession, M&A activity is bound to heat up

Substance over form?

Alston & Bird LLP
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USA
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September 28 2011

Altria lost an appeal from an adverse jury verdict on its SILO and LILO transactions

Cross chain 351?

Alston & Bird LLP
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USA
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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

Late S elections

Alston & Bird LLP
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USA
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September 17 2012

In order for a corporation to be taxed (or not taxed) as an S corporation, it must file an election on Form 2553 no more than two months and 15 days after the beginning of the first year that it wants to be treated as an S corporation

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