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Results: 1-10 of 139

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


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


Spin-offs become easier and easier
  • Alston & Bird LLP
  • USA
  • February 2 2009

Recent government releases show that the section 355 spin-off continues to be a favored corporate transaction, despite Congress' efforts to restrict it in recent years


Surprising interpretation of Alabama Asphaltic
  • Alston & Bird LLP
  • USA
  • March 1 2011

In this recent opinion, the Tax Court substantially reinterpreted the historic opinion of the Supreme Court in Helvering v. Alabama Asphaltic Limestone Co


Economic substance doctrine notice
  • Alston & Bird LLP
  • USA
  • April 5 2012

IRS Notice CC-2012-008 announces new Chief Counsel coordination procedures for assertion of the economic substance doctrine, which incorporate the LB&I Directives previously issued


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


The worthless subsidiary problem
  • Alston & Bird LLP
  • USA
  • January 31 2013

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its


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


An unusual FD(?) reorganization
  • Alston & Bird LLP
  • USA
  • March 1 2014

LTR 201406005 evidently blessed as an F or D reorganization the transfer by a subsidiary of all of its assets to its parent corporation, despite the