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Results: 1-10 of 141

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


Avoiding the section 338 consistency rules
  • Alston & Bird LLP
  • USA
  • April 9 2012

LTRS 201213013 and 201214012 are the same ruling, evidently issued to a buyer and a seller, in the common scenario where the seller consolidated group wants to sell subsidiary stock and the buyer wants to buy assets and obtain a cost basis; both taxpayers got what they wanted, including placing the target corporation into the buying consolidated group, without having a qualified stock purchase and thereby avoiding the consistency rules


Better luck with economic substance doctrine John Hancock Life Insurance Co. v. Commissioner, 141 T.C. No. 1 (2013)
  • Alston & Bird LLP
  • USA
  • September 1 2013

John Hancock Life Insurance lost a recent decision in the U.S. Tax Court ruling on a combination of LILO and SILO transactions that were supposed to


Sections 305 and 306 and tracking stock
  • Alston & Bird LLP
  • USA
  • February 25 2013

LTR 201308001 rules on sections 305 and 306 are bread and butter subchapter C provisions that were designed for "tax shelters" that are so quaint and


Top up options
  • Alston & Bird LLP
  • USA
  • January 11 2012

This article considers the intersection of the corporate law tool known as the “top up option” with the Internal Revenue Code’s section 338, which permits an election that can be favorable after certain corporate stock purchases


CFC’S Subpart F earnings not qualified dividends
  • Alston & Bird LLP
  • USA
  • December 15 2011

On December 7, 2011, The U.S. Tax Court ruled that inclusions in U.S. residents’ gross income that were required under the Subpart F provisions with respect to their controlled foreign corporation’s investments in U.S. property did not constitute qualified dividend income under Section 1(h) (11


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


IRS publishes proposed guidance on foreign government income under Section 892
  • Alston & Bird LLP
  • USA
  • November 15 2011

The IRS has released proposed regulations relating to the taxation of the income of foreign governments from investments in the United States under Section 892


Earnings and profits reductions for 382 limited losses
  • Alston & Bird LLP
  • USA
  • August 10 2011

Section 382 limits the amount of deduction allowed for net operating losses and built in losses subject to section 382(h


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