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Results: 1-10 of 139

Section 304 games
  • Alston & Bird LLP
  • USA
  • October 23 2013

Since the repeal of the collapsible corporation rules, section 304 has been the most confusing corporate tax section in the domestic context. Its


Sections 305 and 306 and tracking stock
  • Alston & Bird LLP
  • USA
  • February 25 2013

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and


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


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


Short sales and CFCs
  • Alston & Bird LLP
  • USA
  • August 1 2012

Short sales are either everyday events or mysterious to most people


STARS transaction rejected
  • Alston & Bird LLP
  • USA
  • February 20 2013

On Feb. 11, 2013, a regular Tax Court opinion was issued in a case that the opinion said was of first impression, ruling against Bank of New York


World’s longest letter ruling
  • Alston & Bird LLP
  • USA
  • November 1 2012

LTR 201240017 is the world’s longest letter ruling, 111 pages in PDF format


Tax officer failed to write his own opinion
  • Alston & Bird LLP
  • USA
  • October 1 2012

The Tax Court applied the economic substance doctrine in Gerdau MacSteel, Inc., 139 TC No. 5 (August 30, 2012), and denied penalty relief in a liability management company “tax shelter” case because the company’s tax department failed to either obtain an outside opinion or write its own


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


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