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Limiting capitalization

Alston & Bird LLP
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USA
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May 13 2013

LTR 201319009 seems to be an odd ruling, because the taxpayer sought a ruling that it had to capitalize certain costs of an acquisition through use

At last: final regulations issued under section 336(e)

Sutherland Asbill & Brennan LLP
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USA
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May 13 2013

In a move that was nearly 27 years in the making, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued long-awaited final

Proposed legislation and pending corporate guidance

Alston & Bird LLP
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USA
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May 1 2013

At a recent D.C Bar Tax Section Corporate Tax Committee meeting, panelistsincluding a Treasury representativediscussed some of the Administration’s

To be or not to be investment income? New York Division of Tax Appeals rules on nature of dividend income used to fund equity compensation plan

Sutherland Asbill & Brennan LLP
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USA
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April 29 2013

The New York State Division of Tax Appeals (DTA) ruled that the dividend income received by a taxpayer holding company from its minority ownership in

Reporting target’s deductions in an acquisition

Bryan Cave LLP
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USA
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April 29 2013

Corporate clients often want a transaction to close at the beginning or end of the day. Generally, the reason for choosing the beginning or end of

Key tax considerations in spin-offs

McDermott Will & Emery
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USA
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April 29 2013

A critical consideration in the disposition of any business is the tax cost. If properly structured, a disposition structured as a spin-off can be

Top five traps for the unwary in spin-offs

McDermott Will & Emery
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USA
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April 29 2013

A wave of corporate breakups has swept through the United States over the last few years as investors have taken notice of the fact that smaller

A Swiss principal model case study: restructuring a multinational corporation to achieve supply chain and tax efficiencies through territorial optimization

Kurtin PLLC
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Switzerland, USA
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April 23 2013

Three years ago, I was asked to serve as lead outside legal counsel to a U.S.-based public corporation in the biotechnology and life sciences sector

What day is it? - IRS speaks out on acquisition deduction issues

Paul Hastings LLP
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USA
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April 18 2013

Corporate tax concerns dictate the structure of many merger and acquisition transactions. A recurring issue in the consolidated tax return context is

Venture funds: don’t fear the LLC

McDermott Will & Emery
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USA
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April 15 2013

It has long been the case that venture funds (classified as partnerships for tax purposes) have insisted that limited liability companies (LLCs

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Search results

Limiting capitalization

At last: final regulations issued under section 336(e)

Proposed legislation and pending corporate guidance

To be or not to be investment income? New York Division of Tax Appeals rules on nature of dividend income used to fund equity compensation plan

Reporting target’s deductions in an acquisition

Key tax considerations in spin-offs

Top five traps for the unwary in spin-offs

A Swiss principal model case study: restructuring a multinational corporation to achieve supply chain and tax efficiencies through territorial optimization

What day is it? - IRS speaks out on acquisition deduction issues

Venture funds: don’t fear the LLC

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