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Results: 1-10 of 139

Cross chain 351?
  • Alston & Bird LLP
  • USA
  • February 1 2012

LTR 201150021 is a surprising cross chain restructuring ruling that treats the transfer of the assets of one subsidiary of P to a subsidiary at the bottom of another chain of subsidiaries below P as a series of section 351 exchanges and a D reorganization at the bottom of the acquiring chain


Loss duplication regulations finalized
  • Alston & Bird LLP
  • USA
  • October 1 2013

Nine years after enactment of Section 362(e)(2) and seven years after proposal of regulations, the Treasury issued final regulations, effective for


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


Unrepatriated foreign earnings
  • Alston & Bird LLP
  • USA
  • June 7 2011

SEC inquired of Sun Hydraulics Corporation how it could project that it would or would not repatriate income and what the tax effect would be


Substance over form?
  • Alston & Bird LLP
  • USA
  • September 28 2011

Altria lost an appeal from an adverse jury verdict on its SILO and LILO transactions


Convertible preferred equity certificates
  • Alston & Bird LLP
  • Luxembourg, USA
  • July 13 2011

Instruments may be treated as debt for foreign income tax purposes but as equity or U.S. tax purposes


An unusual FD(?) reorganization
  • Alston & Bird LLP
  • USA
  • March 1 2014

LTR 201406005 evidently blessed as an F or D reorganization the transfer by a subsidiary of all of its assets to its parent corporation, despite the


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


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