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Results: 1-10 of 138

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

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

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

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

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

Revised temporary regulations under Code sec. 7874 address surrogate foreign corporations

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 15 2009

Treasury and the Internal Revenue Service (IRS) have issued revised temporary regulations under Internal Revenue Code ("Code") section 7874 concerning the determination of whether a foreign corporation is treated as a surrogate foreign corporation

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

Circular flow and F reorganization

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 30 2010

The simplified facts are that Parent owned foreign DRE, which owned foreign Holdco (HCO

Unrepatriated foreign earnings

  • Alston & Bird LLP
  • -
  • USA
  • -
  • June 7 2011

SEC inquired of Sun Hydraulics Corporation how it could project that it would or would not repatriate income and what the tax effect would be

The attractive C corporation

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

In August a major energy company announced that the corporate managing partner would tender to buy out the publicly traded interests in its master