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Non-355 ruling

Alston & Bird LLP
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USA
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December 31 2012

Sometimes, a corporation wants to distribute stock of a subsidiary to its shareholders in a taxable transaction and does not want Section 355 to apply to

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

Year-end dividends

Alston & Bird LLP
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USA
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October 16 2012

Dividends received by December 31, 2012, may be the last dividends in decades to be taxed at a rate as low as 15 percent

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

Bigco acquires small partnership for stock, tax free

Alston & Bird LLP
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USA
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June 4 2012

LTRs 20122014, 20122015, 20122016, and 20122017, are identical rulings showing how the “control immediately after” requirement of section 351 really doesn’t mean that

NCDOR appeals still slow

Alston & Bird LLP
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USA
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June 4 2012

In what is hopefully one of the last of the old modifiable decisions in tax cases by North Carolina Administrative Law judges, the NCDOR allowed the ALJ to relieve a shareholder of transferee tax liability, but still modified the ALJ opinion

North-South spinoffs

Alston & Bird LLP
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USA
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March 9 2012

A North-South spinoff is a section 355 distribution that is accompanied by a contribution of property from the shareholder to the Distributing corporation