Alston & Bird LLP | USA | 2 Sep 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…
Alston & Bird LLP | USA | 1 Oct 2013
Nine years after enactment of Section 362(e)(2) and seven years after proposal of regulations, the Treasury issued final regulations, effective for…
Alston & Bird LLP | USA | 31 Dec 2012
Sometimes, a corporation wants to distribute stock of a subsidiary to its shareholders in a taxable transaction and does not want Section 355 to apply to…
Alston & Bird LLP | USA | 22 Oct 2012
LTR 201242007 is a section 351 ruling with a public offering: not a busted 351, but a good 351.
Alston & Bird LLP | USA | 16 Oct 2012
Dividends received by December 31, 2012, may be the last dividends in decades to be taxed at a rate as low as 15 percent.
Alston & Bird LLP | USA | 1 Oct 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.
Alston & Bird LLP | USA | 4 Jun 2012
In what is hopefully one of the last of the old modifiable decisions in tax cases by North Carolina Administrative Law judges, the NCDOR allowed the ALJ to relieve a shareholder of transferee tax liability, but still modified the ALJ opinion.
Alston & Bird LLP | USA | 4 Jun 2012
LTRs 20122014, 20122015, 20122016, and 20122017, are identical rulings showing how the “control immediately after” requirement of section 351 really doesn’t mean that.
Alston & Bird LLP | USA | 9 Mar 2012
A North-South spinoff is a section 355 distribution that is accompanied by a contribution of property from the shareholder to the Distributing corporation.
Alston & Bird LLP | USA | 24 Feb 2012
Taxpayer sold and leased equipment.