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Results: 1-10 of 139

The Supreme Court, federal taxation and the constitution
  • Alston & Bird LLP
  • USA
  • April 29 2013

In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the


Proposed legislation and pending corporate guidance
  • Alston & Bird LLP
  • USA
  • May 1 2013

At a recent D.C Bar Tax Section Corporate Tax Committee meeting, panelistsincluding a Treasury representativediscussed some of the Administration’s


Inversions and Notice 2014-52
  • Alston & Bird LLP
  • USA
  • October 1 2014

The hottest topic in federal corporate taxation in many years is the corporate inversion. The Treasury Department recently released notice 2014-52


Avoiding Section 382
  • Alston & Bird LLP
  • USA
  • July 5 2011

Taxpayer evidently is publicly held, but has a large shareholder


Circular flow and F reorganization
  • Alston & Bird LLP
  • USA
  • January 3 2011

LTR 201050020 is one of a fairly large number of letter rulings issued recently on novel reincorporation patterns


REIT real property regulation proposed
  • Alston & Bird LLP
  • USA
  • May 20 2014

Prop. Reg. Section 1.856-10 will define real property that will satisfy the income and asset requirements for REITs. It will replace Reg. Section 1


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


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


Statutory interpretation still lives
  • Alston & Bird LLP
  • USA
  • January 1 2014

In early December, the Supreme Court of the United States ruled that the substantial valuation misstatement penalty could be determined in a TEFRA


The worthless subsidiary problem
  • Alston & Bird LLP
  • USA
  • January 31 2013

LPCiminelli Interests, Inc. v. United States, 110 AFTR 2d 2012-6631 (W.D. N.Y. 2012) ruled that a consolidated group did not have to amend its