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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


Rare taxpayer debt-equity win
  • Alston & Bird LLP
  • Netherlands, USA
  • November 28 2012

Pepsico, Inc., and Pepsico Puerto Rico, Inc. v. Commissioner, T.C. Memo 2012-269, ruled that the U.S. holder of an ambiguous security issued by its foreign affiliate did not have to treat the periodic payments received as interest, even though the affiliate was deducting interest paid under Dutch tax law


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


GLAM 2012-007
  • Alston & Bird LLP
  • USA
  • December 1 2012

The IRS Chief Counsel advises the field in this general legal advice memorandum (GLAM) that a subsidiary does not enter a corporate group when the common parent buys the stock needed for affiliation for a note carrying below-market interest so as to compel the seller to exercise its right to take the stock back after two years


Manchester United ruling?
  • Alston & Bird LLP
  • USA
  • October 22 2012

LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351


White knight fees deductible
  • Alston & Bird LLP
  • USA
  • June 1 2009

The Tax Court has ruled that a corporation can deduct a $65 million termination fee it paid to a white knight to end its obligation to be acquired by the white knight and to permit it to accept a hostile offer that produced more value for its shareholders


Obama launches international tax reform proposals to heavy criticism
  • Alston & Bird LLP
  • USA
  • May 15 2009

On May 4, 2009, President Obama unveiled several major international tax proposals that are intended to correct perceived loopholes in current law


Spin-offs become easier and easier
  • Alston & Bird LLP
  • USA
  • February 2 2009

Recent government releases show that the section 355 spin-off continues to be a favored corporate transaction, despite Congress' efforts to restrict it in recent years


Interpreting the Code
  • Alston & Bird LLP
  • USA
  • March 1 2010

A healthy percentage of what tax professionals do is interpreting the Code, the Treasury Regulations and assorted other published guidance


Credit unions under attack
  • Alston & Bird LLP
  • USA
  • September 1 2009

We wrote in 2007 about a series of TAMs in which the IRS had asserted that various income items of exempt credit unions were taxable as unrelated business taxable incomemostly income from non-members and members not directly related to deposits of and lending to members