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Results: 1-10 of 141

Final regulations on disregarded entities involved in conduit arrangements
  • Alston & Bird LLP
  • USA
  • December 15 2011

On December 9, 2011, the IRS published final regulations that address the application of the conduit financing arrangements effected through disregarded entities


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


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


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


Federal tax advisory: Section 336(e) regulations issued
  • Alston & Bird LLP
  • USA
  • August 1 2013

Treasury has exercised its authority under Section 336(e) to write regulations allowing certain sellers of stock to elect to treat certain sales and


N.C. forced combination bill
  • Alston & Bird LLP
  • USA
  • June 9 2011

The elements of the bill are as follows:


1504(a)(4) preferred
  • Alston & Bird LLP
  • USA
  • January 3 2012

Chief Counsel (Corporate) has advised the field that cumulative preferred stock on which the dividend mandatorily cumulated until redemption (and so section 305(c) applied) was section 1504(a)(4) preferred because it did not have a redemption premium (reasonable or unreasonable


North Carolina private letter rulings
  • Alston & Bird LLP
  • USA
  • January 17 2012

Effective February 1, 2012 the NCDOR will charge $5,000 for most answers to taxpayer’s questions through “expedited” letter rulings, and more taxpayers will be forced to seek private letter rulings, because the DOR officers are generally unwilling to give oral advice


Year-end dividends
  • Alston & Bird LLP
  • USA
  • October 16 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


CERT regulation proposed
  • Alston & Bird LLP
  • USA
  • September 17 2012

Twenty three years after it was enacted in 1989, the Treasury issued proposed regulations interpreting section 172(h), the corporate equity reduction transaction (CERT) loss carryback disallowance rule dating from the heyday of the leveraged buyouts