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Section 304 games

  • Alston & Bird LLP
  • -
  • USA
  • -
  • October 23 2013

Since the repeal of the collapsible corporation rules, section 304 has been the most confusing corporate tax section in the domestic context. Its

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

Rare taxpayer debt-equity win

  • Alston & Bird LLP
  • -
  • Netherlands, USA
  • -
  • 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

Short sales and CFCs

  • Alston & Bird LLP
  • -
  • USA
  • -
  • August 1 2012

Short sales are either everyday events or mysterious to most people

Section 871(M) guidance on treatment of dividend equivalent payments

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 15 2012

On January 23, 2012, the IRS published both temporary (T.D. 9572) and proposed regulations (REG- 120282-10) under Section 871(m) regarding U.S. federal withholding tax on dividend equivalents

Top up options

  • Alston & Bird LLP
  • -
  • USA
  • -
  • January 11 2012

This article considers the intersection of the corporate law tool known as the “top up option” with the Internal Revenue Code’s section 338, which permits an election that can be favorable after certain corporate stock purchases

Accelerating income

  • Alston & Bird LLP
  • -
  • USA
  • -
  • December 19 2011

LTR 201150023 allowed a taxpayer to obtain an exemption for income by voluntarily accelerating the income

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

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

Senator Scott Brown declares opposition to $19 billion "bank tax"; House-Senate conference may reconvene

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

Today, Senator Scott Brown (R-MA), one of the few Republicans to vote for passage of the financial reform bill, sent a letter to Senate Banking Committee Chairman Christopher Dodd (D-CT) and House Financial Services Committee Chairman Barney Frank (D-MA) declaring his opposition to the roughly $19 billion "bank tax" on large banks and hedge funds that is included in the recently reconciled Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act