We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 139

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


Tax reform update
  • Alston & Bird LLP
  • USA
  • December 1 2013

Tax reform has been in the offing ever since the 2008 elections. It took a back seat to more pressing national problems for a few years, but calls


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


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


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


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


Statutory interpretation still lives
  • Alston & Bird LLP
  • USA
  • January 1 2014

In early December, the Supreme Court of the United States ruled that the substantial valuation misstatement penalty could be determined in a TEFRA


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


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


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