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Results: 1-10 of 141

The attractive C corporation
  • Alston & Bird LLP
  • USA
  • September 2 2014

In August a major energy company announced that the corporate managing partner would tender to buy out the publicly traded interests in its master


Inversions and Notice 2014-52
  • Alston & Bird LLP
  • USA
  • October 1 2014

The hottest topic in federal corporate taxation in many years is the corporate inversion. The Treasury Department recently released notice 2014-52


Mayo and Chevron
  • Alston & Bird LLP
  • USA
  • February 1 2011

The Supreme Court rejected a challenge to Treasury's 2004 regulation defining a medical resident as a worker and not a student for purposes of FICA taxation


North Carolina tax appeals
  • Alston & Bird LLP
  • USA
  • December 6 2010

The only corporate income tax case in the group is OAH No. 08 REV 2665, decided by the AOH 11162009, decided by the DOR 1222010, and posted on the DOR website in November 2010


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


Limiting capitalization
  • Alston & Bird LLP
  • USA
  • 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


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


Last Granite Trust ruling LTR 201419011
  • Alston & Bird LLP
  • USA
  • June 2 2014

We keep thinking we have seen the last letter ruling allowing a taxpayer to separate a subsidiary liquidation from a preliminary decontrolling stock


REIT real property regulation proposed
  • Alston & Bird LLP
  • USA
  • May 20 2014

Prop. Reg. Section 1.856-10 will define real property that will satisfy the income and asset requirements for REITs. It will replace Reg. Section 1


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