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Supreme Court to review economic substance case
- Alston & Bird LLP
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- USA
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- April 1 2013
United States v. Gary Woods, 471 Fed. Appx. 320 (5th Cir. 2012), affirming per curiam, 794 F. Supp. 2d 714 (WD Tex. 2011), will be reviewed by the
STARS transaction rejected
- Alston & Bird LLP
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- USA
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- February 20 2013
On Feb. 11, 2013, a regular Tax Court opinion was issued in a case that the opinion said was of first impression, ruling against Bank of New York
The worthless subsidiary problem
- Alston & Bird LLP
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- USA
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- 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
GLAM 2012-007
- Alston & Bird LLP
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- USA
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- December 1 2012
The IRS Chief Counsel advises the field in this general legal advice memorandum (GLAM) that a subsidiary does not enter a corporate group when the common parent buys the stock needed for affiliation for a note carrying below-market interest so as to compel the seller to exercise its right to take the stock back after two years
Rare taxpayer debt-equity win
- Alston & Bird LLP
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- Netherlands, USA
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- November 28 2012
Pepsico, Inc., and Pepsico Puerto Rico, Inc. v. Commissioner, T.C. Memo 2012-269, ruled that the U.S. holder of an ambiguous security issued by its foreign affiliate did not have to treat the periodic payments received as interest, even though the affiliate was deducting interest paid under Dutch tax law
Excess loss account avoided
- Alston & Bird LLP
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- USA
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- November 15 2012
LPCiminelli Interests Inc. v. United States (W.D.N.Y. Nov. 13, 2012) ruled for the taxpayer on an IRS assertion of excess loss account liability
Manchester United ruling?
- Alston & Bird LLP
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- USA
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- October 22 2012
LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351
Tax officer failed to write his own opinion
- Alston & Bird LLP
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- USA
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- October 1 2012
The Tax Court applied the economic substance doctrine in Gerdau MacSteel, Inc., 139 TC No. 5 (August 30, 2012), and denied penalty relief in a liability management company “tax shelter” case because the company’s tax department failed to either obtain an outside opinion or write its own
Beware of IRS closing agreements
- Alston & Bird LLP
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- USA
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- August 31 2012
United States v. ConocoPhillips, 2012 WL 3646809 (WD Okla) provides a good illustration on how closing agreements with the IRS are like any other contracts, only moreso, because the IRS is likely to be a particularly unbending contract partner if interpretive issues arise
Tax equal protection
- Alston & Bird LLP
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- USA
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- June 18 2012
Armour v. City of Indianapolis, 132 S. Ct. 2073 (2012) ruled that a city did not violate the Equal Protection Clause of the Fourteenth Amendment when it chose to forgive remaining unpaid installments of a special assessment for sewage improvements but not to refund those taxpayers who had paid in full without choosing to pay in installments
Current Search
- Workarea - Corporate Tax
- Workarea - Litigation
- Author - Jack Cummings
- Jurisdiction - USA
- Firm Name - Alston & Bird LLP