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Results: 1-10 of 141

Important no-rule changes: Rev. Proc. 2014-3
  • Alston & Bird LLP
  • USA
  • February 3 2014

One of the most important bellwethers of what the IRS is thinking is the annual Revenue Procedure that announces the issues on which the IRS


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


NC forced corporate combinations
  • Alston & Bird LLP
  • USA
  • July 19 2011

Session Law 2011-390 “effective 112012” generally repealed the sections of the corporate tax laws on which the Secretary has relied up to now for forced combinations and replaced them with a new regime


NC tax appeals to change
  • Alston & Bird LLP
  • USA
  • July 26 2011

The procedural change is part of a major overhaul of North Carolina administrative law in a bill that the Governor vetoed


IRS publishes proposed guidance on foreign government income under Section 892
  • Alston & Bird LLP
  • USA
  • November 15 2011

The IRS has released proposed regulations relating to the taxation of the income of foreign governments from investments in the United States under Section 892


F reorganizations and double dummies
  • Alston & Bird LLP
  • USA
  • September 1 2012

LTR 201222014 ruled that persons contributing property to a new corporation in exchange for stock can form a control group with other persons contributing the stock of another corporation (target), and therefore enjoy Section 351 nonrecognition treatment


Beware of IRS closing agreements
  • Alston & Bird LLP
  • USA
  • 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


Sections 305 and 306 and tracking stock
  • Alston & Bird LLP
  • USA
  • February 25 2013

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and


STARS transaction rejected
  • Alston & Bird LLP
  • USA
  • 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


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