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Results: 1-10 of 139

The Supreme Court, federal taxation and the constitution
  • Alston & Bird LLP
  • USA
  • April 29 2013

In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the


Proposed legislation and pending corporate guidance
  • Alston & Bird LLP
  • USA
  • May 1 2013

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


Internal spinoffs
  • Alston & Bird LLP
  • USA
  • November 25 2013

LTR 201347005 is a straightforward ruling on multiple internal spin-offs of Controlled holding one of the two businesses of a domestic group. The


Supreme Court to review economic substance case
  • Alston & Bird LLP
  • USA
  • 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


Buying assets
  • Alston & Bird LLP
  • USA
  • November 1 2013

Once upon a time, it was common to sell and buy an ongoing business by deed, bill of sale and assignment and assumption of ongoing contracts. This


PPL and a wealth tax
  • Alston & Bird LLP
  • USA
  • June 3 2013

On May 20, 2013, the Supreme Court of the United States decided PPL Corporation and Subsidiaries v. Commissioner, 569 U.S. __ (2013). This was the


Corporate letter rulings cut back
  • Alston & Bird LLP
  • USA
  • June 26 2013

Rev. Proc. 2013-32, issued on June 25, 2013, substantially restricts the scope of letter rulings that taxpayers can obtain from Chief Counsel


Two Supreme Court tax decisions
  • Alston & Bird LLP
  • USA
  • August 1 2014

During the current term, the Supreme Court of the United States decided very few tax cases. Two of those seem quite limited in scope, until you delve


Non-355 ruling
  • Alston & Bird LLP
  • USA
  • 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


Federal tax advisory - eliminating a domestic sandwich LTR 201250004
  • Alston & Bird LLP
  • USA
  • January 1 2013

LTR 201250004 involved a domestic corporate Parent's purchase of a foreign group that had one domestic subsidiary. This is a common situation and Parent