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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


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


Buying assets
  • Alston & Bird LLP
  • USA
  • November 1 2013

Once upon a time, it was common to sell and buy an ongoing business by deed, bill of sale and assignment and assumption of ongoing contracts. This


Economic substance doctrine bill: unanswered questions
  • Alston & Bird LLP
  • USA
  • July 1 2009

The bill aims to resolve or inform two, and only two, uncertainties that Congress believes the courts encounter when applying what the bill calls the “economic substance doctrine” to federal income tax disputes


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


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


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


Erroneous sales tax collections in North Carolina
  • Alston & Bird LLP
  • USA
  • February 24 2012

Taxpayer sold and leased equipment


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