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Reorganization plan qualifies for bankruptcy exception to NOL limitation rules
  • Morrison & Foerster LLP
  • USA
  • April 30 2013

In another recent private letter ruling, the IRS ruled that an ownership change pursuant to a bankruptcy reorganization plan qualified for an

No costs allowed to petitioner who challenged a sales tax assessment
  • Morrison & Foerster LLP
  • USA
  • December 5 2011

A New York State Administrative Law Judge has denied an application for costs and fees filed by a petitioner who had succeeded in substantially reducing the asserted tax liability through settlement

Partnership bankruptcy tax issues
  • Cadwalader Wickersham & Taft LLP
  • USA
  • June 26 2015

Bankruptcies and restructurings involving partners and partnerships raise a number of unique tax issues. While the Internal Revenue Service

Ad valorem property taxes: deadline for challenging in a bankruptcy
  • Pepper Hamilton LLP
  • USA
  • December 11 2012

Under Section 505(a)(1) of the Bankruptcy Code, generally a bankruptcy court may determine the amount or legality of any tax

Treasury issues final regulations on partnership interests transferred to creditor in debt-for-equity exchange
  • Dentons
  • USA
  • November 21 2011

On November 15, 2011, the U.S. Internal Revenue Service and the U.S. Department of Treasury issued final regulations under Section1 108(e)(8) and certain other Sections relating to the application of Section 108(e)(8) to partnerships

Lenders should consider suggesting bankruptcy to borrowers following the sale of delinquent taxes on a principal residence
  • Dykema Gossett PLLC
  • USA
  • January 31 2014

The Seventh Circuit Court of Appeals recently held that a plan under chapter 13 of the Bankruptcy Code can modify the rights of a purchaser of

LeClairRyan accountant and attorney liability newsbrief - Spring 2014
  • LeClairRyan
  • USA
  • June 5 2014

Within one day of each other, the U.S. District Court for the District of Massachusetts (“District Court”) in Perkins v. Massachusetts Department of

Delinquent property tax collection: foreclosure may be vulnerable
  • Pepper Hamilton LLP
  • USA
  • September 25 2012

Wisconsin has a strict tax foreclosure procedure in which the tax authority effectively obtains the property without any public or competitive bidding in satisfaction of the delinquent tax bill

Bankruptcy PLR with NOL preservation result
  • Pepper Hamilton LLP
  • USA
  • August 14 2012

Section 382 limits a loss corporations ability to use its Net Operating Losses (NOLs) carryforwards following an "ownership change."

International regulatory update 10-14 December 2012
  • Clifford Chance LLP
  • European Union, Germany, Hong Kong, Italy, Spain, United Kingdom, USA
  • December 17 2012

The European Council (Heads of State or Government) has published the conclusions from its meeting on 13 and 14 December 2012, at which it agreed on a roadmap for the completion of the Economic and Monetary Union