TreatiseTreatise

The Corporate Tax Practice Series: Strategies for Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings

 by Louis S Freeman
 
 Copyright: 2010-2018
 Last Updated: February 2018

 Product Details >> 

Product Details

  • ISBN Number: 9781402415104
  • Page Count: 41604
  • Number of Volumes: 31
  •  

With contributions from more than 435 of the world’s leading tax practitioners, including former Internal Revenue Service and Department of Treasury officials, the 31-volume The Corporate Tax Practice Series is the definitive resource on corporate tax. The treatise begins with a “General Overview and Strategies in Representing Sellers,” written by Series Editor Louis S. Freeman, and continues with in-depth coverage of cutting-edge corporate tax strategies and issues, from Section 355 divisive strategies to the exposures created by the Foreign Account Tax Compliance Act (FATCA). Important historical perspectives on tax legislation, rules, regulations and case law are discussed to provide context for the topics.

Major topics include:

  • Drafting and negotiating acquisition agreements
  • Contingent liabilities in taxable acquisitions
  • The use of partnerships and LLCs in M&As
  • Workouts, debt exchanges and other restructuring issues
  • Special issues presented by S Corporations
  • Transferring intellectual property
  • International tax issues, including CFCs, PFICs, FIRPTA, FATCA, foreign tax credits, tax treaties and transfer pricing
  • Taxation of financial products
  • Tax shelters, the economic substance and business purpose doctrines, anti-abuse rules and tax penalties
  • The consolidated return regulations
  Table of Contents
Chapter 1: General Overview and Strategies in Representing Sellers: Part I
Chapter 1A: General Overview and Strategies in Representing Sellers: Part II
Chapter 1B: General Overview and Strategies in Representing Sellers: Part III
Chapter 1C: Basic Tax Issues in Acquisition Transactions
Chapter 1D: New York State Bar Association Tax Section Report on the Proposed Regulations Under Section 1411
Chapter 1E: Proposed Net Investment Tax Regs' Impact on Alternatives
Chapter 1F: Description of Certain Revenue Provisions Contained in the President’s Fiscal Year 2015 Budget Proposal (JCS-2-14)
Chapter 1G: Overview of the Federal Tax System as in Effect for 2017 (JCX-17-17)
Chapter 1H: Present Law and Background Information Related to the Taxation of Capital Gains (JCX-72-12)
Chapter 2: Negotiating the Stock Sale of a Business: Corporate and Drafting Aspects
Chapter 3: Selling the Private Company
Chapter 4: Structuring the Deal—Taxable, Tax-Free or a Little of Both?
Chapter 5: Drafting and Negotiating the Tax Provisions of the Acquisition Agreement
Chapter 6: SFAS No. 142 Makes Its Debut
Chapter 7: FASB Proposal: FASB Proposes an Overhaul of How We Account for Business Combinations
Chapter 8: FASB Discloses Proposal to Change the Accounting for Business Combinations That Feature Contingent Consideration
Chapter 9: FASB Decisions Continue to Erode Goodwill
Chapter 10: FASB’s Proposal for SPEs
Chapter 11: SFAS No. 142 Disclosures Are Revealing
Chapter 12: A CEO’s and CFO’s Guide to the Effect of Taxes on Deal Terms and the Acquisition Agreement
Chapter 13: The Tax Lawyer’s Perspective on Acquisition Agreements
Chapter 14: Diligence, Negotiation and Drafting Merger & Acquisition Agreements with a Focus on Tax Matters
Chapter 15: Negotiating Tax Provisions in Merger and Acquisition Agreements
Chapter 16: Tax and Tax-Related Provisions of U.S. Stock Purchase Agreements
Chapter 17: The Tax Due Diligence Process and Negotiating and Drafting Tax Provisions in Acquisition Agreements
Chapter 17A: The Taxation of Tax Indemnity Payments from Clark to Cosentino
Chapter 18: Negotiating Merger and Acquisition Agreements
Chapter 19: Due Diligence: State and Local Tax Aspects
Chapter 20: Overview of State and Local Taxation
Chapter 22: State and Local Tax Aspects of Corporate Acquisitions
Chapter 23: Impact of Sales and Use Taxes on Corporate Transactions
Chapter 24: State and Local Income and Franchise Tax Aspects of Corporate Acquisitions
Chapter 26: The Impact of Legal Entities on the Mechanics of Unitary Reporting
Chapter 27: Section 338
  • • : Appendix27-387
Chapter 28: Section 338(h)(10)
  • • : Appendix28-163
Chapter 29: Structuring Stock and Asset Acquisitions—Section 338 and Other Selected Issues
Chapter 30: Section 338(h)(10)
Chapter 30A: Section 336(e) Regulations
Chapter 30B: An Analysis of the Section 336(e) Regulations
Chapter 30C: A Survey of the Long Awaited 336(e) Regulations; Work Still Needs to Be Done
Chapter 30E: Final Regulations on Qualified Stock Dispositions
Chapter 30F: New York State Bar Association Tax Section Letter Response: Proposal to Modify Regulations Under Section 336(e) and Section 338
Chapter 30G: American Bar Association Section of Taxation Comments on Regulations Enabling Elections for Certain Transactions Under Section 336(e)
Chapter 30H: American Bar Association Section on Taxation Comments on Section 336(e)
Chapter 31: Purchase Price Allocation Rules: Sections 1060, 338 and 197
Chapter 32: Intangibles 2014: Past, Present, and Future
Chapter 34: Capitalization of Amounts Paid to Acquire or Create Intangibles and to Facilitate Certain Capital Transactions
Chapter 36: The Final INDOPCO Regulations: An Outline of Their Application in the M&A Context
Chapter 38: Present Law and Background Relating to the Interaction of Federal Income Tax Rules and Financial Accounting Rules (JCX-13-12)
Chapter 39: Tax Treatment of Reorganization Costs
Chapter 40A: Background and Present Law Relating to Cost Recovery and Domestic Production Activities (JCX-19-12)
Chapter 41: The Treatment of Contingent Consideration in Taxable Acquisitions
Chapter 42: The Tax Treatment of Earnouts in Business Acquisitions
Chapter 42A: A Financial and Income Tax Analysis of Earnouts
Chapter 43: Traps and Opportunities Involving Contingent Purchase Price Acquisitions: Why Does Something So Simple Have to Be So Complicated?
Chapter 43A: Taxation of Earn-Outs in Public Company Acquisitions: New CVRs Raise Unsettled Tax Issues
Chapter 44: Contingent Consideration, Contingent Liabilities and Indemnities in Acquisitions
Chapter 45: Contingent Liabilities in Taxable Asset Acquisitions
Chapter 46: The Treatment of Contingent Liabilities in Taxable Acquisitions
Chapter 46A: Choice of Business Entity: Present Law and Data Relating to C Corporations, Partnerships, and S Corporations (JCX-71-15)
Chapter 46B: Assumed Liability Deductions
Chapter 46C: New York State Bar Association Tax Section Report on Treatment of "Deferred Revenue" by the Buyer in Taxable Asset Acquisitions
Chapter 47: The Partnership Union: Opportunities for Joint Ventures and Divestitures
Chapter 48: Opening Pandora’s Box: Who Is (or Should Be) a Partner?
Chapter 49: Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 51: A Layman’s Guide to LLC Incentive Compensation
Chapter 52: Section 83(b), Section 409A, Section 457A and Subchapter K
Chapter 53: Rev. Proc. 2001-43, Section 83(b), and Unvested Profits Interests—The Final Facet of Diamond?
Chapter 54: Proposed Regulations on Partnership Equity for Services Create Problems and Opportunities
Chapter 55: Proposed Partnership Equity Compensation Regulations: “Little or No Chance” of Satisfying Everyone
Chapter 56: Navigating the Partner/Employee Dichotomy and SECA Tax Rules
Chapter 57: Partners as Employees: A Proposal for Analyzing Partner Compensation
Chapter 58: Taxing Partnership Profits Interests as Compensation Income
Chapter 58A: Camp's Plan for Carried Interest: One Step Forward, One Step Back
Chapter 59: New York State Bar Association Tax Section Report on Proposed Carried Interest and Fee Deferral Legislation
Chapter 60: Employee Benefits Considerations in Joint Ventures
Chapter 61: The “Check-the-Box” Regulations: Elective Entity Classification Under Section 7701
Chapter 61A: Defining “Partnership” for Federal Tax Purposes: Reconciling Culbertson §704(e)(1), and Check-the-Box
Chapter 62: Disregarded Entities in Corporate Transactions
Chapter 63: Use of Limited Liability Companies in Corporate Transactions
Chapter 64: A Disregarded Entity Must Be Taken into Account
Chapter 67: Section 197 and Partnership Transactions
Chapter 68: Final Section 197 Regulations: Application to Partnership Transactions
Chapter 70: Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 71: The Impact of a Capital Account Deficit Restoration Obligation on a Partner’s At-Risk Amount and Share of Liabilities: Hubert Enterprises, Inc. v. Commissioner
Chapter 72: Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 73: Selected Tax Allocation Problems for Partnerships and LLCs
Chapter 74: Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 75: A 'Guaranteed' Debacle: Proposed Partnership Liability Regulations
Chapter 76: An Analysis of the Rules Governing Partnership Allocations with Respect to Contributed Properties: The Final Regulations Under Section 704(c)
Chapter 77: Section 704(c) Allocations: Choices and Consequences
Chapter 78: Select Section 704(c) Issues with Respect to Partnership Revaluations (PowerPoint slides)
Chapter 78A: The Proposed Regulations Under Sections 704(c)(1)(C), 734, 743, and 755
Chapter 79: An Analysis of the Rules Governing Disguised Sales to Partnerships: Section 707(a)(2)(b)
Chapter 80: Partnership Disguised Sale Rules
Chapter 81: New Proposed Regulations on Disguised Sales of Partnership Interests
Chapter 82: Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
Chapter 82A: Tax Court Goes Overboard in Canal
Chapter 83: Final Regulations Under Sections 704(c)(1)(B), 737, and 731(c)
Chapter 84: Creative Partnership Exit Strategies
Chapter 85: Partnership Mixing-Bowl Issues (PowerPoint slides)
Chapter 87: Deceptive Simplicity: Continuing and Current Issues with Guaranteed Payments
Chapter 88: Operational Issues of Section 751(b)—Current and Future (PowerPoint slides)
Chapter 89A: Let's Get Technical: Partnership Termination
Chapter 90: Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 91: Partnership Mergers and Divisions: A User’s Guide
Chapter 92: Partnership Mergers: The Saga Continues
Chapter 93: Applying Sections 704(c) and 737 in Partnership Mergers and Divisions
Chapter 94: Mergers & Divisions of Partnerships
Chapter 95: Transactional Planning Under the Partnership Merger & Division Regulations
Chapter 96: M&A Transactions Involving Partnerships and LLCs, Including Conversions, Mergers and Divisions
Chapter 96A: New York State Bar Association Tax Section Report on Revenue Ruling 99-6
Chapter 97: Partnerships in the Public Space
Chapter 98: Partnership Bankruptcy Tax Issues
Chapter 99: New Legislation Tightens Partnership Tax Rules
Chapter 99A: Developments in Partnership and Real Estate Taxation in 2014
Chapter 100: Recent Developments in Partnership Taxation
Chapter 100A: Recent Developments in Partnership and Real Estate Taxation in 2011
Chapter 100B: But How Is That Rule Applied in a Tiered Partnership Structure?
Chapter 100C: Partnerships with Reportable Entity Partners
Chapter 101: Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss
Chapter 102: Through the Looking Glass: Seeing Corporate Problems as Partnership Opportunities
Chapter 103: Corporate Allocations and Their Constraints: Allocating the Income of Corporate Pass-Through Entities
Chapter 104: Entity Identity: The Taxation of Quasi-Separate Enterprises
Chapter 105: Tax Classification of Segregated Portfolio Companies
Chapter 106: The Elective Large Partnership Rules
Chapter 107: Select Transactional Issues in State Partnership Taxation
Chapter 109: Delaware Statutory Trusts and 1031: A Marriage Made in Heaven or Just a Pipe Dream?
Chapter 110: Privatizing Our Infrastructure: Taxing the Toll or Tolling the Tax
Chapter 112: The Application of the Unrelated Business Tax to Securities and Other Investments by Tax-Exempt Organizations
Chapter 113: Taxation of United States Tax-Exempt Entities’ Offshore Hedge Fund Investments: Application of the Section 514 Debt-Financed Rules to Leveraged Hedge Funds and Derivatives and the Case for Equalization
Chapter 114: Joint Ventures with REITs and Tax-Exempt Entities
Chapter 116: A Guide to Election Year Activities of Section 501(c)(3) Organizations
Chapter 117: The S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
  • • : Appendix117-235
Chapter 118: Tax Considerations for Buyers and Sellers of S Corporations
Chapter 118A: S Corporation Acquisition Techniques
Chapter 119: Special Problems and Considerations—S Corporation as Target in M&A Transactions
Chapter 120: When Subchapter S Meets Subchapter C
Chapter 120A: Section 336(e) and S Corporations: Another Way to Treat a Stock Sale as an Asset Sale
Chapter 120B: Something Not So Simple: Sale of S Corporation Stock or Assests for Contingent Payment Obligations
Chapter 120C: Closely Held Businesses: The Complete Anatomy of a Qualified Subchapter S Subsidiary Election—Not Just the Nuts and Bolts
Chapter 121: Legal Standards for Adoption of Executive Compensation Programs and Contacts
Chapter 121A: Compensation Issues in M&A Transactions
Chapter 122: Revisiting Golden Parachutes
Chapter 123: ABC’s of Section 280G
Chapter 124: Restricted Stock Notes
Chapter 125: Chapter 3: Substantial Risk of Forfeiture
Chapter 126: Taxation of Service-Connected Property Transfers Under Code Section 83
Chapter 127: Consideration or Compensation? Reflections on Rev. Rul. 2007-49
Chapter 128: Qualified Plans
  • • : Appendix128-71
Chapter 129: Present Law and Background Relating to the Tax Treatment of Retirement Savings (JCX-44-11)
Chapter 129A: Present Law and Background Relating to Tax-Favored Retirement Saving and Certain Related Legislative Proposals (JCX-3-16)
Chapter 129B: Commentary to Model Equity Compensation Plan Exempt from Section 409A
Chapter 130: Federal Tax Aspects of Mergers, Acquisitions, Buyouts, Mgmt Comp, Workouts, & Takeovers (PowerPoint slides)
Chapter 131: Structuring Corporate Acquisitions—Tax Aspects
Chapter 131B: Personal Goodwill: Possible Escape from Double Taxation or More
Chapter 131C: Use of Formula Clauses for Income Tax Advantage
Chapter 132: What Is a Merger?: The Case for Taxing Cash Mergers Like Stock Sales
Chapter 134: Current Developments in Tax-Free Corporate Reorganizations
Chapter 135: Current Developments in Tax-Free and Taxable Acquisitions and Separations
Chapter 136: Corporate Mergers, Acquisitions, and Reorganizations
Chapter 137: An Overview of Certain U.S. Federal Income Tax Considerations Regarding Taxable and Tax-Free Corporate Acquisition Structures
Chapter 138: Restricting Stock in Reorganizations
Chapter 139: New York State Bar Association Tax Section Report on Proposed Regulations Regarding Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities
Chapter 140: New York State Bar Association Tax Section Report on Selected Issues in Triangular Reorganizations
Chapter 141: Rebooting Section 356: Part 1—The Statute; Part 2—The Regulations
Chapter 142: Corporate E&P and Section 356
Chapter 143: Whither Business Purpose?
Chapter 143A: The Phantom Business Requirement
Chapter 144: Continuity of Interest and Continuity of Business Enterprise Regulations
Chapter 145: The Pre-Reorganization Continuity of Interest Regulations
Chapter 147: The Evolution of the Continuity of Interest Test, General Utilities Repeal, and the Taxation of Corporate Acquisitions
Chapter 148: New York State Bar Association Tax Section Report on the Proposed Continuity of Interest Regulations
Chapter 150: New York State Bar Association Tax Section Letter Response: Formal Guidance for Stock Buybacks and “North South” Transactions
Chapter 150A: New York State Bar Association Tax Section Report on Proposed Anti-Loss Importation Regulations Under Sections 362(e)(1) and 334(b)(1)(B)
Chapter 150B: Coping with Loss: The Anti-Loss Importation and Duplication Rules
Chapter 151: Selected Tax Considerations in Corporate Restructurings
Chapter 152: Underwater Assets and Insolvent Corporations: Reflections on Treasury’s Recently Proposed Regulations and Related Matters
Chapter 153: Assessing the Value of the Proposed “No Net Value” Regulations
Chapter 155: The Direction of a Merger—Federal Income Tax Consequences
Chapter 156: “The End Result Test” Revisited
Chapter 157: The “Downstream Merger” into Less Than 80% Controlled Subsidiaries: Fact or Fiction
Chapter 157A: Application of the Step Transaction Doctrine in the Corporate Setting
Chapter 158: Triple Taxation
Chapter 159: New York State Bar Association Tax Section Report on the Kimbell-Diamond Doctrine
Chapter 160B: New York State Bar Association Tax Section Report on Characterizing “Overlap” Transactions Under Subchapter C
Chapter 160D: Big A, Little C: Baby Steps Toward Modernizing Reorganizations
Chapter 161: Acquisitive D Reorganizations
Chapter 162: Bottoms Up: Tiered D Reorganizations
Chapter 163: The Future of Acquisitive D Reorganizations
Chapter 163A: Triple-Drop-and-Check Transactions: Reflections on the Interaction of the All Boot “D” Reorganization Regulations with Revenue Ruling 78-130
Chapter 163B: Using Intercompany Debts as Assets
Chapter 164: Some Ado About a Nothing: Final F Reorganization Regulations
Chapter 164A: Stepping Out of Line
Chapter 165: Recent Developments in the Step Transaction Doctrine
Chapter 166: Multiple Step Acquisitions: Dancing the Tax-Free Tango
Chapter 167: Dethroning King Enterprises
Chapter 168: Another Kimbell-Diamond Article!
Chapter 170A: E&P Allocation and Reorganizations?
Chapter 171: Developments, Theories and Themes in Stock Basis
Chapter 171A: Selecting the Right Target Basis Calculation for Your Basis Transfer Transaction
Chapter 172: Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Stock or Securities (PowerPoint slides)
Chapter 173: Plantation Patterns: A Review of the Case Law and Open Issues
Chapter 174: Tax Planning with Non-Compensatory Options
Chapter 175: Tax Treatment of Cashless Warrant Exercises
Chapter 176: Exchanges of Warrants in Reorganizations
Chapter 177: New York State Bar Association Tax Section Letter Response: Request for Formal Guidance on the Tax Consequences of Warrant Exercises
Chapter 178: Dealing with Contingent Stock and Contingent-Liabilities in Tax-Free Transactions
Chapter 179: Special Considerations in the Mergers and Acquisitions of Regulated Investment Companies
Chapter 181: REIT Mergers & Acquisitions—Tax Consequences
Chapter 182: Taxation of Real Estate Investment Trusts and Shareholders
Chapter 182A: Determining U.S. Real Property Holding Corporation Status
Chapter 183: Taking REITs Private: Selected Tax Issues
Chapter 183A: Private REITs in the Public Sphere
Chapter 184: Certain Tax Issues in M&A Transactions Involving Insurance Companies
Chapter 184A: Insurance Tax Issues in Mergers and Acquisitions: Identifying and Preserving Value and Avoiding Subchapter L Surprises
Chapter 185: RICs and the Retail Investor: A Marriage of Convenience or Necessity?
Chapter 185A: The Corporation as Partner Tax Reasons and Tax Effects
Chapter 185B: New York State Bar Association Tax Section Report No. 1355 on Temporary and Proposed Regulations under Section 337(d) and Section 732(f)
Chapter 186: Recent Developments Affecting Investors in Life Insurance
Chapter 188: Organizing the Corporate Venture
Chapter 189: Tax Planning for Section 351 Transactions
Chapter 190: Transfers of Property to and Distributions and Redemption of Stock in Closely Held Corporations
Chapter 195: Determining the Character of Section 357(c) Gain
Chapter 196: Assumptions of “Liabilities” in Taxable and Non-Taxable Transactions
Chapter 197: Liability Assumptions—Section 357(d)
Chapter 198: Investment Company Limitations for Corporations and Partnerships
Chapter 199: Exchange Funds: What Is Diversification?
Chapter 200A: Granite Trust Planning: Properly Adopting a Plan of Liquidation
Chapter 200B: An Incomplete Liquidation Provision: Section 332 (d)
Chapter 201: Section 355: Divisive Strategies Discussion Problems (PowerPoint slides)
Chapter 202: Corporate Distributions Under Section 355
Chapter 203: Corporate Divisions Under Section 355
Chapter 204: Tax Free Spin-Offs Under Section 355
Chapter 205: The Section 355 Edifice Spin-Offs: Past, Present and Future
Chapter 206: Section 355: Tax-Free Spin-Offs, Split-Offs, Split-Ups—Uses and Requirements
Chapter 206A: The Gregory Rules of Section 355 Business Purpose Active Trade or Business Device (with Additional Thoughts on Control, Continuity of Interest, and Other Section 355 Miscellany)
Chapter 206C: REIT Spin-Offs: Passive REITs, Active Businesses
Chapter 206D: New York State Bar Association Tax Section Report on Notice 2015-59 and Revenue Procedure 2015-43 Relating to Substantial Investment Assets, De Minimis Active Trades or Businesses and C-to-RIC Spin-Offs
Chapter 206E: New York State Bar Association Tax Section Report No. 1356 on Proposed Regulations under Section 355 Concerning the Device Prohibition and Active Trade or Business Requirement
Chapter 206F: Proposed Regs Modify Device and Active Trade or Business Analysis
Chapter 207: New York State Bar Association Tax Section Report on the Role of the Step Transaction Doctrine in Section 355 Stock Distributions: Control Requirements and North-South Transactions
Chapter 207A: Spin-Off Auditing, Opinions, and Rulings
Chapter 207B: E&P Spin-Offs—Part 2
Chapter 207C: New York State Bar Association Tax Section Report on the Allocation of Earnings and Profits in Connection with Divisive Transactions
Chapter 208: Hot Stock
Chapter 208A: Spin-Offs: Continuing Relationships Between Distributing & Controlled
Chapter 209: The Business Purpose Requirement of Section 355
Chapter 210: The Evolving Business Purpose Requirement for Spin-Off Transactions
Chapter 211A: The Elusive Sponsored Spin-Off
Chapter 212: Allocation of E&P in a Spin-Off by a Consolidated Group: New Developments Answer Some Questions but Leave Many Unanswered
Chapter 213: The Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute
Chapter 214: Final Regulations Under Section 1.355-6
Chapter 216: “Spin-Offs”: The Anti-Morris Trust and Intragroup Spin Provisions
Chapter 217: The Fourth Time’s a Charm—Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers
Chapter 218: Final Section 355(e) Plan Regulations—The Final Chapter in the Saga
Chapter 220: New York State Bar Association Tax Section: Report on Distributions in Connection with Acquisitions
Chapter 221: The Tax Consequences of Certain Major Corporate Distributions
Chapter 222: Corporate Earnings and Profits: Selected Issues
Chapter 223: Federal Income Tax Considerations in Going Private Transactions
Chapter 227: The Revised Section 305 Regulations: Past, Present and Future
Chapter 227B: Comeback Victory: The IRS Issues Final Dividend Equivalent Regulations
Chapter 227C: Withholding on Air: The IRS Imposes Withholding Tax Rules for Adjustments on Convertible Debt and Equity
Chapter 227D: New York State Bar Association Tax Section Report No. 1351 on Proposed Regulations under Section 305(c)
Chapter 228: Convertible Preferred Stock Investments by Private Funds: A Practical Guide to Tax Structuring
Chapter 229: Understanding Venture Capital Structure: A Tax Explanation for Convertible Preferred Stock
Chapter 230: Tax Considerations for Venture Capital and Technology-Related Start-Ups
Chapter 230A: Tax Incentives for Research, Experimentation, and Innovation (JCX-45-11)
Chapter 231: Revival of the Choice of Entity Analysis: Use of Limited Liability Companies for Start-Up Businesses and the “Up-C” Structure
Chapter 232: Exploring the Reasons Behind the Bias of Private Equity and Venture Capital Firms Investing in Corporations Rather Than Limited Liability Companies—A Time to Reconsider
Chapter 233: Selected Tax Issues in Structuring Private Equity Funds
Chapter 233A: Playing with Blocks: Testing a Fund’s Blocker Allocations
Chapter 233D: The Substance of Dividends Received Deductions
Chapter 233E: Tax Risks of Investment Funds' Currency Management
Chapter 233F: Sun Capital's Limited Impact on the Taxation of Private Equity Funds
Chapter 234: Code Sec. 1032—Taking Stock of the Situation
Chapter 235: The Zero Basis Problem as a Result of the Issuance of Stock or Debt
Chapter 236: Zero Basis in the Taxpayer’s Own Stock or Debt Obligations: Whether Such Instruments Constitute “Property”
Chapter 236A: Strange Loops and Tangled Hierarchies
Chapter 237: Summaries by Code Section of Selected Subchapter C Revenue Rulings
Chapter 239C: Interesting Transactions of 2012
Chapter 239D: Interesting Transactions of 2013
Chapter 239E: Interesting Transactions of 2014
Chapter 239F: Interesting Transactions of 2015
Chapter 239G: Interesting Transactions of the Past Year
Chapter 240: Tax & Accounting Issues Biannual
Chapter 241: Tracking Tracking Stock
Chapter 242: Virtual Mergers
Chapter 244: Canadian Exchangeable Share Transactions and Foreign Transaction Forms
Chapter 245: Equalization Arrangement or Optimization Arrangement: A Brief Updated Summary
Chapter 247A: A Gambit Vanquished: The Rise and Fall of the “Killer B”
Chapter 248: U.S. Private Equity Funds Making Cross-Border Investments
Chapter 249: Cross-Border Tax Problems of Investment Funds
Chapter 251: A Primer on PFIC Taxation
Chapter 251A: PFIC Issues for Non-U.S. Property Operating Companies
Chapter 252: Global Tax-Free Deals: Mergers, Acquisitions and Spins at Home and Abroad
Chapter 253: Internal Revenue Service LB&I International Practice Service Concept Unit
Chapter 254: Tax Strategies for Selling Foreign Subsidiaries
Chapter 255: Section 1248: Taxation of the Disposition of Stock of a CFC
Chapter 256: Basic U.S. Tax Considerations in Buying or Selling a Non-U.S. Business
Chapter 257: Buyers Electing Section 338 for CFC Targets: Sellers Beware
Chapter 258: Cross-Border Acquisition Patterns Implicating Section 338: Recommendations for Reform
Chapter 258A: Section 338 Elections in the Age of Covered Asset Acquisitions
Chapter 259: Selected Tax Issues in Outbound Investment by United States Persons
Chapter 259A: Navigating the U.S. Tax Rules When Starting or Expanding a Business Overseas
Chapter 260A: Present Law and Background Related to Proposals to Reform the Taxation of Income of Multinational Enterprises (JCX-90-14)
Chapter 261: Tax Due Diligence for International Operations
Chapter 261A: An Update and Refresher on Tax Reporting for Cross-Border Transactions—Forms, Penalties, Statute of Limitations, Possible Defenses
Chapter 262: Financing Foreign Subsidiaries of U.S. Multinationals
Chapter 263: A Quick Guide to Common International Reorganizations Under Section 367
Chapter 263A: A Primer on Section 367: Basic Rules and Policies
Chapter 265: Tax-Deferred Reorganization Acquisitions of U.S. Corporations by Foreign Corporations Under Treas. Reg. Sec. 1.367(a)-3(c)
Chapter 266: Final GRA Regulations Issued February 10, 2009, Reg. §1.367(a)-8
Chapter 267A: Back to the Future: Reconsidering Section 367(d)
Chapter 267B: Majority Staff Report Impact of the U.S. Tax Code on the Market for Corporate Control and Jobs
Chapter 268: Corporate Inversions: Yesterday, Today, and Tomorrow
Chapter 268A: Corporate Expatriation, Inversions, and Mergers: Tax Issues
Chapter 269: Present Law and Recent Global Developments Related to Cross-Border Taxation (JCX-8-16)
Chapter 270: The Anti-Inversion Provisions of Internal Revenue Code Section 7874
Chapter 270B: New York State Bar Association Tax Section Report on Temporary Regulations Under Section 7874
Chapter 270C: A Gambit Renewed: IRS Targets “Killer Bs” Paired with Inversions
Chapter 273: Partnerships Change Everything: Using a Partnership in an Outbound Stock Acquisition
Chapter 274: Outbound Acquisitions: Holding Companies of Europe—A Guide for Tax Planning or a Road Map for Difficulty? (2016)
Chapter 275: US International Tax Issues in E-Commerce
Chapter 276: IRS Takes Controversial Approach to Characterization of Separately Stated Item of Subpart F Income
Chapter 277: Planning Techniques Described in the Treasury’s Subpart F Study
Chapter 277B: Active Financing Made Permanent, But Questions Remain
Chapter 278: IRS Takes Sound Approach to Applying CFC Look-Through Rule
Chapter 279: Intragroup Transactions: The Kinder, Gentler Subpart F
Chapter 280: Section 965 Update
Chapter 281: Avoiding Subpart F Income Through Manufacturing Services Arrangements
Chapter 282: Section 956: Investment in U.S. Property
Chapter 282A: The Tax Impact of Investments in U.S. Property by a CFC
Chapter 283: Guidance Under Section 956: A Small Part of the Solution to the Lending Drought
Chapter 283A: A Renewed Focus on Section 956
Chapter 284: Pledges and Guarantees in Loan Agreements
Chapter 284A: Present Law and Selected Proposals Related to the Repatriation of Foreign Earnings (JCX-96-15)
Chapter 284B: American Bar Association Section of Taxation Letter Response: Comments on Exclusion from Gross Income of Previously Taxed Earnings and Adjustments to Basis of Stock in CFCs Under Sections 959 and 961
Chapter 285: The Direct and Indirect Foreign Tax Credit and the Foreign Tax Credit Limitation
Chapter 285A: Limitations on the Ability to Credit Foreign Taxes Under Sections 909, 901(m), and 960(c)
Chapter 285B: New York State Bar Association Tax Section Report on Section 901(m)
Chapter 285D: Foreign Tax Law: Its Relevance in Resolving U.S. Tax Law Issues
Chapter 286: Helpful Overall Foreign Loss, Separate Limitation Loss, and Overall Domestic Loss Regulations Still Leave Open Issues
Chapter 287: Deconstructing Section 905(c): An Examination of the Redetermination Rules After TRA 1997
Chapter 288: Dual Consolidated Losses
Chapter 289: A Company Without a Country: The Ambiguous World of Dual Consolidated Losses
Chapter 291: “All or Nothing Rule” Leaves Taxpayers Empty-Handed
Chapter 294: Tax Planning for the Provision of Cross-Border Services
Chapter 295: Assignment of Corporate Opportunities—The Migration of American Intangibles
Chapter 296: Marketing Intangibles Require Close Legal and Tax Scrutiny
Chapter 298: Treasury Department Suggests Transfer Pricing Revisions
Chapter 299: Expanding Transfer Pricing Conflict Resolution: China–Taiwan Trade
Chapter 300: Negotiating an Advance Pricing Agreement
Chapter 301: Global Documentation—Many Considerations Ten Years Later
Chapter 302: Global Transfer Pricing Documentation: The 10-Year Update
Chapter 303: Background, Summary, and Implications of the OECD/G20 Base Erosion and Profit Shifting Project (JCX-139-15)
Chapter 304: The Arm’s Length Standard After Altera and BEPS
Chapter 305: A Primer to Understand the BEPS Project Without the Gory Details
Chapter 306: Cost Sharing Developments in the U.S.: The Arm’s Length Standard After Xilinx and Veritas
Chapter 314: Reform of U.S. International Taxation: Alternatives
Chapter 315: Present Law and Selected Policy Issues in the U.S. Taxation of Cross-Border Income (JCX-51-15)
Chapter 316: Source of Royalty Income and Place of Use of Intangible Property
Chapter 317: Treaty Consistency
Chapter 317A: Application of Fiscal Transparency Principles to Treaty Limitations on the Branch Profits Tax
Chapter 317B: From Uncle Sam with Love: Treaty Benefits in Inbound Tax Planning
Chapter 318: New York City Bar Report Offering Proposals Regarding the “Derivative Benefits” Provisions Found in the Limitation on Benefits Article of Certain Income Tax Treaties
Chapter 320: Moving 'Management and Control’ of a Foreign Corporation to Achieve Favorable U.S. Tax Results
Chapter 321: Tax Planning for Foreign Inbound Investments and Business Activities: An Analytical Overview
Chapter 321A: Consolidating Acquired IP—A U.S. Inbound Perspective
Chapter 322: U.S. Income Taxation of Foreign Persons Engaged in a U.S. Trade or Business
Chapter 322A: Present Law and Background Related to U.S. Activities of Foreign Persons (JCX-37-11)
Chapter 322B: Tax-Savvy Investing in ASEAN Nations
Chapter 323: Prepared by the Staff of the Joint Committee on Taxation: Economic and U.S. Income Tax Issues Raised by Sovereign Wealth Fund Investment in the United States
Chapter 324: Chapter 14: A Primer on the U.S. Taxation of Sovereign Wealth Funds
Chapter 325A: New York State Bar Association Tax Section Proposed Regulations Under Section 892
Chapter 326: Investment in U.S. Real Estate by Sovereign Wealth Funds—Tax Issues
Chapter 327: New York City Bar Report Offering Proposed Guidance Regarding U.S. Federal Income Tax Treatment of Certain Lending Activities Conducted within the United States as Reported by the Committee on Taxation of Business Entities
Chapter 329: Peculiarities of 80/20 Company Taxation
Chapter 330: Opportunities for the Foreign Investor in United States Real Estate—If Planning Comes First
Chapter 332: The Trade or Business Issue for Foreign Portfolio Investors: From Safe Harbors to Troubled Waters
Chapter 333: U.S. Taxation of Foreign Portfolio Investors
Chapter 334: Is There a FIRPTA Tax or Withholding on REIT Distributions Attributable to Sales of USRPIs?: Section 897(h)(1) and New Section 1445(e)(6)
Chapter 335: Issuing Bonds to Non-U.S. Investors: Finding the Path Through the Tax Maze
Chapter 335H: New York State Bar Association Tax Section Report on the FATCA Final Regulations: PFFI Rules; IGAs; Interaction Between the Regulations and Chapter 3 and 61
Chapter 336: U.S. Earnings Stripping Rules in the International Context: Yesterday, Today and Tomorrow
Chapter 336A: Testing for Thin Capitalization Under Section 163(j): A Flawed Safe Harbor
Chapter 336B: Tax Challenges (and Opportunities) in Financing Investments into the U.S.
Chapter 336C: Overview of the Tax Treatment of Corporate Debt and Equity (JCX-45-16)
Chapter 337: International Joint Ventures: Basic Tax Goals and Structures
Chapter 338: Foreign Partnerships Cross Border Planning
Chapter 339: U.S. Taxation of Foreign Partners
Chapter 339A: In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K)
Chapter 340: Selected Federal Income Tax Issues Arising in Corporate Debt Restructurings
Chapter 341: Debt Exchanges
Chapter 342: Modifying Debt and Its Consequences
Chapter 343: Mission Creep: The Expanding Role of Debt Modification Regulations
Chapter 343A: Significant Modification of Debt Instruments: A Case Study
Chapter 343B: American Bar Association Section of Taxation Comments on Modifications of Debt Instruments under Section 1001
Chapter 344: New York State Bar Association Tax Section Report on the Taxation of Distressed Debt
Chapter 345: Selected Issues Relating to the Election to Defer COD Income
Chapter 346: Cancelation of Debt and Related Transactions
Chapter 346A: The Taxation of Distressed Debt Investments: Taking Stock
Chapter 347: Restructuring Troubled Companies
Chapter 348: Disregarded Entities and Debt Modifications
Chapter 350: Another Look Through the Worthless Stock Deduction: Section 165(g)(3) as Applied to Foreign Subsidiaries
Chapter 351: FDIC Assisted Transactions: Section 597 Redux
Chapter 352: [Reserved]
Chapter 353: New York City Bar Report Regarding Proposals for Accounting Treatment of Interest on Non-Performing Loans
Chapter 354: Selected Federal Income Tax Issues Affecting Cross-Border Debt Restructurings
Chapter 355: Debt Workouts: The Partnership and the Partners
Chapter 356: Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships
Chapter 357: Allocation of COD Income in Partnership Workouts
Chapter 358: Revenue Ruling 2012–14: The IRS Lends a Helping Hand to Insolvent Partners
Chapter 359: Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses
Chapter 360: Worthless Partnership Interests
Chapter 360A: Is There Alchemy When Debt Disappears in Partnership Contribution/Distribution Transactions? (PowerPoint slides)
Chapter 361: Application of Cancellation of Debt Rules to Consolidated Groups (PowerPoint slides)
Chapter 362: Consolidated Attribute Reduction Regulations
Chapter 364: New York State Bar Association Tax Section Report on Claiming Worthlessness for a Failed Subsidiary Within a Consolidated Group
Chapter 367: Restructuring the Bankrupt Corporation
Chapter 370: Fixed and Contingent Claims in Bankruptcy—Liquidating Trusts and Partnerships
Chapter 371: Trafficking in Net Operating Losses: What’s So Bad? An Assessment of Net Operating Loss Carryover Limitations
Chapter 372: Preservation and Use of Net Operating Losses and Other Corporate Tax Attributes
Chapter 373: Section 382
Chapter 374: Limitations on Corporate Tax Attributes: An Analysis of Section 382 and Related Provisions
Chapter 374A: New York State Bar Association Tax Section Report on Notice 2010-49
Chapter 375: Section 382: Fluctuation in Value
Chapter 375A: Small Comfort: The Final "Small Shareholder" Regulations Under Section 382
Chapter 375B: New York State Bar Association Tax Section Report on Application of Treasury Regulation Section 1.382-2T(f)(18)(iii) with Respect to Distressed Debt
Chapter 375C: New York State Bar Association Tax Section Report on the Proposed Regulations Under Section 172(h) Relating to Corporate Equity Reduction Transactions
Chapter 376: Comments Concerning Notice 2003-65 Under Section 382 of the Internal Revenue Code Regarding the Treatment of Recognized Built-in Gains and Losses
Chapter 378: Section 384 of the Internal Revenue Code of 1986
Chapter 379: Be Careful What You Wish for: Is Section 382’s Treasure Section 384’s Trash?
Chapter 380: Distinguishing Sales from Financings and Debt from Equity
Chapter 380A: What Role for Equality in Applying Factors for Distinguishing Debt?
Chapter 380B: Documentation Rules Round 2—A Taxpayer Project for 2016 Not 2018
Chapter 381A: New York State Bar Association Tax Section Report on Proposed Regulations on the Definition of Public Trading
Chapter 381B: Present Law and Background Relating to Tax Treatment of Business Debt (JCX-41-11)
Chapter 381C: New York State Bar Association Tax Section Report No. 1366 on Possible Regulations Interpreting Rules Governing Applicable High Yield Discount Obligations
Chapter 382: Taxation of High-Yield Debt—Beware the End of the Reprieve
Chapter 382A: Relevance of the OID Principles in Applying the AHYDO Rules
Chapter 384: A Brief Primer on Debt Instruments with Contingent Payments
Chapter 385: Contingent Interest Convertible Bonds and the Economic Accrual Regime
Chapter 387: The Demise of CoCos and the Tax Consequences of Exchanging Convertible Debt
Chapter 388: What Looks the Same May Not Be the Same: The Tax Treatment of Securities Reopenings
Chapter 389: Tax Deductible Equity: The Quest for The Holy Grail—Part II
Chapter 390: Equity, Debt, Not—The Tax Treatment of Non-Debt Open Transactions
Chapter 391: Income Trusts and Income Deposit Securities: The U.S. Tax Perspective
Chapter 392: Everything I Know About New Financial Products I Learned from DECS
Chapter 393: Present Law and Issues Related to the Taxation of Financial Instruments and Products (JCX-56-11)
Chapter 394: New York State Bar Association Tax Section Report on Prepaid Forward Contracts
Chapter 395: Who Should Be Ringing Their Hands Over Phones: Wall Street or Washington?
Chapter 396: Tax Consequences of Business and Investment- Driven Uses of Financial Products
Chapter 397: The Financial Product Tax Reform Proposals
Chapter 398: Capital Ideas: The History of the Treatment of Derivative Gains and Losses
Chapter 398A: New York State Bar Association Tax Section Report on Certain Aspects of the Taxation of Securities Loans and the Operation of Section 1058
Chapter 398B: Taxation of Securities Futures Contracts
Chapter 399: New Tax Issues Arising from the Dodd-Frank Act and Related Changes to Market Practice for Derivatives
Chapter 399A: The Taxation of Dodd-Frank
Chapter 400: United States Federal Taxation of Derivatives: One Way or Many?
Chapter 401: Rationalizing the Taxation of Options in the Age of Derivatives
Chapter 402: Constructive Sales Under Section 1259: The Best Is Yet to Come
Chapter 403: Financial Products Exchangeable into Common Stock: Tax Opportunities and Issues
Chapter 404: Prepaid Forward Contracts and Equity Collars: Tax Traps and Opportunities
Chapter 405: Where Are They, Again? Foreign Currency Questions from the World of Structured Notes
Chapter 406: Proposed Straddle and Hedging Regulations Take Steps in the Wrong Direction
Chapter 407: Do What I Say, Not What I Do: The US Internal Revenue Service Finalizes Changes to the Mixed Straddle Rules
Chapter 408: ABCs of Cross-Border Derivatives
Chapter 411: Taxation of Equity Derivatives
Chapter 414: Contextual Analysis of Tax Ownership
Chapter 417: Selected Tax Issues Affecting Domestic and Cross-Border Securitization Transactions
Chapter 418: The Way (Securitization) Things Ought to Be
Chapter 419: The Frame Game: How Defining the “Transaction” Decides the Case
Chapter 420: Tax Shelters: Appropriate Tax Minimization Planning and Compliance vs. Abusive Tax Avoidance Transactions and Penalties
Chapter 421: A Short History of Tax Shelters
Chapter 421A: Valero II: District Court Alters Its Views on “Tax Shelters”
Chapter 421B: Bad Facts Result in a Taxpayer Loss in First SILO Case
Chapter 421C: Consolidated Edison—A LILO Transaction Succeeds on the Facts
Chapter 421D: Court of Federal Claims Rejects Taxpayer’s Claims of Business Purpose in Heinz
Chapter 421E: IRS Successfully Challenges a Midco Transaction in Enbridge
Chapter 421F: Wells Fargo Loses a SILO Case
Chapter 421G: ‘Son of Boss' Update: Summary Judgment on the Tax Liability in Cemco but No Fraud in Sala
Chapter 421H: LILO Transaction Upset by District Court on Motion for Summary Judgment in BB&T
Chapter 421I: Castle Harbour III: A Taxpayer Victory as the District Court Refuses to Surrender
Chapter 421J: CA-7 Sinks Penalties in One Son-of-Boss Case, While Reg. 1.752-6 Is Torpedoed Again in Another
Chapter 421K: No ‘Bliss’ in New Phoenix Sunrise—Tax Court Rejects and Penalizes a Tax Shelter Transaction
Chapter 421L: What Will Be the Impact of the Government’s Economic Substance Victory in Coltec?
Chapter 422: CNT Investors and the Judicial Doctrines
Chapter 422A: “Codification” of Economic Substance—Much Ado About Nothing?
Chapter 423: Antiabuse Rules and Policy: Coherence or Tower of Babel?
Chapter 424: MIDCO Transactions and the Expanding Universe of Transferee Liability
Chapter 425: Double Deductions: Duquesne and Thrifty Oil
Chapter 426: A Principal Purpose: There Can Be Only One
Chapter 427: Compaq: Find Another Poster Child: The Business Purpose Doctrine Is Alive and Well in the Fifth Circuit
Chapter 428: A New Form of Obscenity? Sorting Through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec
Chapter 429: Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 429A: Countryside: The Tax Court Rejects the IRS Challenge to the Economic Substance of a ‘Real Deal’
Chapter 429B: Circular Cash Flows and the Federal Income Tax
Chapter 431: The Economic Substance Doctrine in Federal and State Taxation
Chapter 431A: New York State Bar Association Tax Section Report on Codification of the Economic Substance Doctrine
Chapter 432: The Relevance Games: Congress's Choices for Economic Substance Gamemakers
Chapter 432A: Economic Substance Doctrine in the United States
Chapter 433: The Future of Tax Planning? From Coltec and “You Know It When You See It” to Schering-Plough and “Assimilation with Applicable Tax Laws”
Chapter 434: The Tax Court in Barnes Group Misapplies the Step Transaction Doctrine, Imposes Penalties
Chapter 434A: The STARS Continue to Shine—Wells Fargo Prevails on Various Motions
Chapter 434B: Tax Shelters and the Decline of the Rule of Law
Chapter 434C: BNY and AIG—Using Economic Substance to Attack Transactions the Courts Do Not Like
Chapter 434D: Castle Harbour V—The Government Loses (Again) in the District Court
Chapter 434E: Chemtech—The Fifth Circuit Reins in but Upholds the District Court
Chapter 434F: Federal Circuit Upsets a LILO Deal, and Maybe the Law on Step Transactions and Substance Over Form
Chapter 434G: New Guidance Sheds Light on Economic Substance Doctrine and Related Penalties
Chapter 434H: John Hancock—The Tax Court Applies Judicial Doctrines to SILOs and LILOs
Chapter 434I: The STARS Are Not Aligned: Courts Split in Assessing an Alleged Tax Shelter Transaction
Chapter 434J: The STARS Continue to Revolve—the First Appellate Decision
Chapter 435: Disclosure, Listing and Registration Rules for “Potentially Abusive Tax Shelters"
Chapter 437A: Final Regulations for the Tax Shelter Disclosure Regime—Making the Rules More User Friendly
Chapter 438: To Disclose or Not to Disclose: Tax Shelters, Penalties, and Circular 230 in 2015
Chapter 438A: Announcement 2010-9: Transparency or Overkill?
Chapter 439: The New Penalty Regime: Proceed with Caution
Chapter 439A: The Final Section 6694 Regulations: New Rules for the Preparer Penalty
Chapter 439B: Preparer Penalties: The Service’s ‘Interim’ Response to the Section 6694 Amendments
Chapter 440: ‘Tough Loving’: District Court Invalidates IRS Regulation of Return Preparers
Chapter 440A: The Regulation of Tax Advice and Advisors
Chapter 440C: New Ethical Guidance in Revisions to Circular 230 Will Affect All Tax Practitioners
Chapter 440D: Loving It: Appellate Court Confirms IRS Overstepped in Regulating Return Preparers
Chapter 441: Ethical Disclosure Requirements in Corporate Tax Representation
Chapter 441B: The Best Defense Is a Good Defense—Compliance and Defensive Tax Practice in the International Business and Tax Areas (Ethical Considerations in Light of Dynamic and Sometimes Conflicting Values)
Chapter 443: Navigating an OPR Disciplinary Proceeding
Chapter 444: IRS Finalizes Revisions to Circular 230
Chapter 444A: The Tax Professional as the Target Du Jour in Criminal Tax Investigations
Chapter 447: Consolidated Return Issues for Buyers and Sellers in M&A Transactions
Chapter 448: The Consolidated Return Investment Basis Adjustment Rules
Chapter 449: The Consolidated Return Investment Basis Adjustment Rules—Study Problems
Chapter 450: The Consolidated Unified Loss Rules
Chapter 451: A Survey of §1.1502-36
Chapter 452: Coordinating §1.1502-11, §1.1502-28, and §1.1502-36
Chapter 456: The Consolidated Return Anti-Loss Duplication Rule
Chapter 456A: Section 1.1502-13 (c)(6)(ii)(C): Limiting Gain Duplication on Member Stock
Chapter 458: Intercompany Transaction Regulations
Chapter 459: The Regulations Governing Intercompany Transactions Within Consolidated Groups
Chapter 460: Intercompany Transaction Problems
Chapter 461: Comparison of the Intercompany Obligation Rules Under Former Treas. Reg. §1.1502-13(g) (1995), Former Prop. Treas. Reg. §1.1502-13(g) (1998), and Treas. Reg. §1.1502-13(g) (2008)
Chapter 462: The Consolidated Group: Continuation and Termination Issues
Chapter 463: Group Continuation Rules/Continued Filing Requirement (PowerPoint slides)
Chapter 465: “Anti-Freeze”—Consolidated Return Anti-Avoidance, Anti-Stuffing, and Anti-Stripping Rules Designed to Chill Tax Planning
Chapter 467: The Section 382 Consolidated Return Regulations
Chapter 469: Consolidated Return Treatment of Financially Troubled Members
Chapter 470: Why Marvel Was Wrongly Decided and Its Impact in Consolidation
Chapter 471: The SRLY Loss Rules: Life After Section 382
Chapter 472: Life After the Final Regulations: Consolidated Section 382 and SRLY
Chapter 473: What Happens When Tax Mistakes Are Made—Equity in the Tax Law
Chapter 473A: Back in Time: In Search of a Coherent Theory of Transactional Retroactivity
Chapter 474: Revisionist History: Retroactive Federal Tax Planning
Chapter 475: Privileged Communications in the Context of U.S. Tax Practice
Chapter 476A: In-House Perspectives on Considerations to Protect Privilege with Respect to Tax Related Materials
Chapter 477: Corporate Income Tax Controversies: Procedures and Strategies for Audits, Appeals and Trials
Chapter 479: FIN 48—Uncertain Tax Positions for Books and Now Tax Returns
Chapter 482: A First Look at 2007 Schedule M-3 Reporting by Large Corporations
Chapter 482A: Schedule UTP: A New U.S. Filing Obligation May Cause Additional Consternation in Transfer Pricing Matters
Chapter 482B: Schedule UTP—Why So Few Disclosures?
Chapter 482C: A First Look at 2010 Schedule M-3 Reporting and Schedule UTP
Chapter 482D: 2010–2011 Schedule M-3 Profiles and Schedule UTP Filing Status
Chapter 482E: A First Look at 2012 Schedule M-3 Reporting and Multinational Type
Chapter 482F: Schedule M-3 Profiles of Schedule UTP Filers by IRC Section Cited
Chapter 483: Partnership with Reportable Entity Partners
Chapter 485: History of the Office of Chief Counsel
Chapter 486A: 9100 Relief
Chapter 494: Background on Business Tax Reform (JCX-35-16)
Chapter 495: Overview of Approaches to Corporate Integration (JCX-44-16)
Chapter 496: Corporate Tax Integration: In Brief
  Index to Vol. 1
  Index to Vol. 2
  Index to Vol. 3
  Index to Vol. 4
  Index to Vol. 5
  Index to Vol. 6
  Index to Vol. 7
  Index to Vol. 8
  Index to Vol. 9
  Index to Vol. 10
  Index to Vol. 11
  Index to Vol. 12
  Index to Vol. 13
  Index to Vol. 14
  Index to Vol. 15
  Index to Vol. 16
  Index to Vol. 17
  Index to Vol. 18
  Index to Vol. 19
  Index to Vol. 20
  Index to Vol. 21
  Index to Vol. 22
  Index to Vol. 23
  Index to Vol. 24
  Index to Vol. 25
  Index to Vol. 26
  Index to Vol. 27
  Index to Vol. 28
  Index to Vol. 29
  Index to Vol. 30
  Index to Vol. 31

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