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

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


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


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


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


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


The Supreme Court, federal taxation and the constitution
  • Alston & Bird LLP
  • USA
  • April 29 2013

In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the


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


D reorganization basis regulations finalized
  • Alston & Bird LLP
  • USA
  • November 1 2014

In November the Treasury finalized a temporary and proposed regulation dealing with the basis of stock of the target corporation in a nondivisive D


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