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Lack of income tax deduction for payment of breakup fees
  • Alston & Bird LLP
  • USA
  • July 1 2010

As the country moves out of the recession, M&A activity is bound to heat up


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


Important no-rule changes: Rev. Proc. 2014-3
  • Alston & Bird LLP
  • USA
  • February 3 2014

One of the most important bellwethers of what the IRS is thinking is the annual Revenue Procedure that announces the issues on which the IRS


Closing a prepaid forward with a short sale
  • Alston & Bird LLP
  • USA
  • October 24 2012

TAM 201214021 appears to reconsider an issue addressed in CCA 201104031, issued about a year earlier


North-South spinoffs
  • Alston & Bird LLP
  • USA
  • March 9 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


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


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


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


NC tax appeals to change
  • Alston & Bird LLP
  • USA
  • July 26 2011

The procedural change is part of a major overhaul of North Carolina administrative law in a bill that the Governor vetoed


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