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