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Results: 1-10 of 139

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


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


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


The attractive C corporation
  • Alston & Bird LLP
  • USA
  • September 2 2014

In August a major energy company announced that the corporate managing partner would tender to buy out the publicly traded interests in its master


Inversions and Notice 2014-52
  • Alston & Bird LLP
  • USA
  • October 1 2014

The hottest topic in federal corporate taxation in many years is the corporate inversion. The Treasury Department recently released notice 2014-52


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


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


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


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


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