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Results: 1-10 of 139

Section 355 no-rule tightened
  • Alston & Bird LLP
  • USA
  • January 2 2013

The IRS issued its annual no-ruling revenue procedure, Rev. Proc. 2013-3, which added several items relating to Section 355 distributions. The IRS is


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


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


Loss duplication regulations finalized
  • Alston & Bird LLP
  • USA
  • October 1 2013

Nine years after enactment of Section 362(e)(2) and seven years after proposal of regulations, the Treasury issued final regulations, effective for


REIT conversions
  • Alston & Bird LLP
  • USA
  • June 7 2013

LTR 201314002 has caused quite a buzz in the investment community. Stock pickers want to know how far the envelope can be pushed on the definition of


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


Global banks being audited
  • Alston & Bird LLP
  • USA
  • January 7 2013

All global banks currently being audited by the IRS, which have engaged in cross-border withholding planning for clients, should take careful notice of AM


Federal tax advisory: Section 336(e) regulations issued
  • Alston & Bird LLP
  • USA
  • August 1 2013

Treasury has exercised its authority under Section 336(e) to write regulations allowing certain sellers of stock to elect to treat certain sales and


Manchester United ruling?
  • Alston & Bird LLP
  • USA
  • October 22 2012

LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351