BNA INSIGHTS: Covered Asset Acquisition Proposal: Sanctioning International Double Taxation?

Proposed legislation in the American Jobs and Closing Tax Loopholes Act of 2010 (H.R. 4213; hereinafter the “Bill”) would deny…

IRS Unveils Major Guidance on Ownership Changes Under Section 382, Wins Praise

The Internal Revenue Service June 11 unveiled major guidance on ownership changes under tax code Section 382 that practitioners said…

BNA INSIGHTS: Did IRS Misuse ‘Step’ Doctrine in Revenue Ruling 2008-25?

Robert Willens, president of tax and consulting firm Robert Willens LLC, examines Revenue Ruling 2008-25, in which IRS concluded a transaction did not qualify as…

BNA INSIGHTS: Repatriation: Insuring Basis Recovery

Private Letter Ruling 201014048 held that a Section 302/301 redemption of stock by a controlled foreign corporation from what until recently was its sole shareholder “will be treated as…

IRS, Treasury Working on Consolidated Groups Guidance Under Net Operating Loss Carryback

The Internal Revenue Service and Treasury Department soon will issue guidance to address issues for consolidated groups raised by the recently enacted five-year net operating loss carryback…

Reorganizations, Intercompany Debt Addressed in Private Letter Rulings

The Internal Revenue Service in private letter rulings regarding corporate reorganizations released April 23 addressed transactions constituting “A” and “D” reorganizations, as well a transaction undertaken by…

BNA INSIGHTS: Another Domestic Sandwich

This article examines a remarkable ruling that assists a taxpayer in claiming a current loss deduction, and possibly an ordinary loss deduction, on the stock of a foreign subsidiary even though…

ANALYSIS: Corporate Reorganizations: Having and Eating Your Cake and Getting Paid for It Too

Private Letter Ruling 201011003 allowed the following array of tax benefits as a result of the insolvency of a subgroup in a consolidated group…

ANALYSIS: When Will Preliminary Distributions Impact Continuity of Interest?

In order for a transaction to qualify as a “reorganization,” it must, among other things, exhibit “continuity of interest” (COI); in fact, Treasury Regulations Section 1.368-1(b) provides that “requisite to a reorganization under the Internal Revenue Code are a continuity of business enterprise …

ANALYSIS: Intragroup Reorganizations Addressed in IRS Corporate Public Letter Rulings of Note

Jasper L. Cummings, Jr. of Alston & Bird LLP examines three recent letter rulings that address recurrent issues of rescission, liquidation-reincorporation, the recipient of the reorganizing corporation’s tax attributes…

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