We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

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

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

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

Economic substance doctrine expands

  • Alston & Bird LLP
  • -
  • USA
  • -
  • November 29 2010

Sundrup operated a trucking business as a proprietorship

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

Intercompany accounts require maintenance

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 1 2009

Corporate groups almost universally designate one member as the "banker" and arrange for all of the group’s cash to be swept into the banker’s account, which is carefully managed by the group’s treasury function

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

Inversions and Notice 2014-52

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

The hottest topic in federal corporate taxation in many years is the corporate inversion. The Treasury Department recently released notice 2014-52

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

IRS may apply economic substance doctrine to securities lending transactions entered to avoid U.S. withholding tax

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 15 2013

In generic legal advice released in November 2012 (AM 2012-009), the Chief Counsel's Office, applying the economic substance doctrine, disregarded a