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Results: 1-10 of 139

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


Better luck with economic substance doctrine John Hancock Life Insurance Co. v. Commissioner, 141 T.C. No. 1 (2013)
  • Alston & Bird LLP
  • USA
  • September 1 2013

John Hancock Life Insurance lost a recent decision in the U.S. Tax Court ruling on a combination of LILO and SILO transactions that were supposed to


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


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


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


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 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


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 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


Internal spinoffs
  • Alston & Bird LLP
  • USA
  • November 25 2013

LTR 201347005 is a straightforward ruling on multiple internal spin-offs of Controlled holding one of the two businesses of a domestic group. The