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Results: 1-10 of 137

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

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

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

The worthless subsidiary problem

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 31 2013

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its

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

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

NC tax appeals to change

  • Alston & Bird LLP
  • -
  • USA
  • -
  • July 26 2011

The procedural change is part of a major overhaul of North Carolina administrative law in a bill that the Governor vetoed

Section 305(b)(2) warrants

  • Alston & Bird LLP
  • -
  • USA
  • -
  • April 2 2012

LTR 201213011 rules that a domestic corporation can generate a section 301 distribution to its shareholder(s), possibly for the purpose of creating capital gain, possibly to allow use of an expiring capital loss of the shareholder

Statutory interpretation still lives

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

In early December, the Supreme Court of the United States ruled that the substantial valuation misstatement penalty could be determined in a TEFRA

Important no-rule changes: Rev. Proc. 2014-3

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 3 2014

One of the most important bellwethers of what the IRS is thinking is the annual Revenue Procedure that announces the issues on which the IRS