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28 results found

Article

Fox Rothschild LLP | USA | 11 Apr 2012

Treasury and Internal Revenue Service issue new temporary regulations on "all cash" Type D reorganizations

In TD 9558, issued late last year, Temporary Regulations were promulgated on the determination of the basis of stock or securities in a reorganization where no stock or securities of the issuing corporation are issued and distributed in the transaction, and, in particular, the treatment of “all cash D reorganizations”.

Article

Fox Rothschild LLP | USA | 1 Nov 2011

Will JASA become more forthcoming in disclosing its substantial losses and risks from investing with Madoff? - Installment 62

Installment 61 of this blog series on Madoff discussed the $5.2 million clawback lawsuit (the “JASA Lawsuit”) recently filed by Trustee Irving Picard against Jewish Association for Services for the Aged (“JASA”), reaffirming the perplexing and inconsistent manner, virtually to the point of arbitrariness and unfairness, with which Picard has handled charities that invested with Madoff.

Article

Fox Rothschild LLP | USA | 24 Jul 2011

Tax Court rules that securities transaction did not qualify under Section 1058: decision follows on the heels of the Tax Court's recent decisions under Section 1058 in anshutz (135 T.C. No.5) and Carroway (135 T.C. No. 3) decided last year

In Henry Samueli et al v. Commissioner, 132 T.C. No. 4 (2011), the Tax Court, per Judge Kroupa’s opinion for the majority, in response to the petitioners and respondent (IRS) filing of cross motions for summary judgment in a consolidated proceeding, upheld the Service’s deficiencies in income tax for denying the taxpayers interest deductions claimed on the underlying “margin loans” used to acquire the securities, were disallowed on the basis the purported payments of “interest” were not made with respect to an actual debt

Article

Fox Rothschild LLP | USA | 7 Jun 2011

Treasury and IRS issue final regulations under Section 367(b) for certain triangular reorganizations: "the Killer B" regulations.

In May, 2008, temporary and proposed regulations were issued under 367(b) to address the Service's concern about the tax impacts arising from certain triangular reorganizations involving foreign corporations, aka "Killer B" transactions, in which a subsidiary purchases, in connection with the reorganization, stock of its parent corporation in exchange for property, and exchanges the parent corporation's stock for the stock or property of a target corporation.

Article

Fox Rothschild LLP | USA | 25 Mar 2011

Madoff and charities: the Lautenberg Foundation 2009Fform 990-PF - part 2 - installment 50

This is the fiftieth in a series of installments on this blog that are discussing issues arising in the aftermath of the Ponzi scheme perpetrated by Bernard L. Madoff (“Madoff”).

Article

Fox Rothschild LLP | USA | 16 Mar 2011

Why the time for security and privacy insurance has arrived

You may think that a $30 USB drive does not seem like the most costly business asset you could lose, but you would be wrong.

Article

Fox Rothschild LLP | USA | 19 Nov 2010

Federal law excludes 100 of gains on qualified small business stock acquired by December 31, 2010

On September 27, 2010, President Obama signed the Small Business Jobs Act of 2010 aimed at encouraging investment in small businesses.

Article

Fox Rothschild LLP | USA | 15 Nov 2010

Madoff and charities: the Lautenberg Foundation files its past due 2008 Form 990-PF- Installment 41

This is the forty-first in a series of installments on this blog that are discussing some of the issues arising in the aftermath of the Ponzi scheme perpetrated by Bernard L.

Article

Fox Rothschild LLP | USA | 22 Oct 2010

Mutual fund's income from a controlled foreign corporation constitutes qualifying income for purposes of Section 851(b)(2)

Taxpayers-mutual funds or RICs filed ruling request seeking favorable determination from the National Office of the Internal Revenue Service that income derived from each Fund's investments in a wholly-owned subsidiary that is a controlled foreign corporation (CFC) constitutes qualifying income under 851(b)(2).

Article

Fox Rothschild LLP | USA | 23 Aug 2010

Madoff and charities: some due diligence on the investment adviser for Howard Hughes Medical Institute - Ivy Asset Management LLC - Installment 34

This is the thirty-fourth in a series of Installments on this blog that discusses issues that arose in the aftermath of the Bernard L. Madoff (“Madoff”) scandal.

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