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Results: 1-10 of 139

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


N.C. budget enacted; franchise tax change
  • Alston & Bird LLP
  • USA
  • June 16 2011

The budget act does not contain many substantive tax changes, and rather is limited to budget matters


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


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


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


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


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


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


Federal tax advisory: Hook Stock
  • Alston & Bird LLP
  • USA
  • May 1 2015

Hook stock is stock issued by a parent corporation and held by its subsidiary. That does not seem very complicatedat first. We can imagine that


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