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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


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


North Carolina private letter rulings
  • Alston & Bird LLP
  • USA
  • January 17 2012

Effective February 1, 2012 the NCDOR will charge $5,000 for most answers to taxpayer’s questions through “expedited” letter rulings, and more taxpayers will be forced to seek private letter rulings, because the DOR officers are generally unwilling to give oral advice


All-cash D regulation amended
  • Alston & Bird LLP
  • USA
  • December 1 2011

On November 18, 2011, the Treasury filed an amendment to the final regulations published in 2009 that address what is known as the all-cash D reorganization


Hobby losses and movies
  • Alston & Bird LLP
  • USA
  • May 1 2012

This new Tax Court decision allows a lawyer to avoid the hobby loss rule and currently deduct the costs of making a documentary movie that might be said to be “for fun,” and interprets for the first time Section 181 (enacted in 2004), which permits deduction rather than capitalization of domestic movie production costs


Avoiding the section 338 consistency rules
  • Alston & Bird LLP
  • USA
  • April 9 2012

LTRS 201213013 and 201214012 are the same ruling, evidently issued to a buyer and a seller, in the common scenario where the seller consolidated group wants to sell subsidiary stock and the buyer wants to buy assets and obtain a cost basis; both taxpayers got what they wanted, including placing the target corporation into the buying consolidated group, without having a qualified stock purchase and thereby avoiding the consistency rules


Monetizing losses
  • Alston & Bird LLP
  • USA
  • January 23 2012

LTR 201203004 illustrates how to split up a public company’s two businesses, while monetizing the tax losses of one of the businesses so that it can have a better chance to survive


Tax equal protection
  • Alston & Bird LLP
  • USA
  • June 18 2012

Armour v. City of Indianapolis, 132 S. Ct. 2073 (2012) ruled that a city did not violate the Equal Protection Clause of the Fourteenth Amendment when it chose to forgive remaining unpaid installments of a special assessment for sewage improvements but not to refund those taxpayers who had paid in full without choosing to pay in installments


Closely held Section 305 issues
  • Alston & Bird LLP
  • USA
  • March 1 2012

Section 305 is an antique weapon that mostly misfires


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