Author Archives: Jasper L. (Jack) Cummings, Jr.

Jasper L. (Jack) Cummings, Jr.
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.  Read More

Tax Change Planning

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With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking. Tax Reform Act of 1986 Payment of dividends and stock buybacks Less advantageous structures Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Dual-Class Stock Blessing for Spin

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A new Letter Ruling from the IRS brings concerns for corporations looking at a spinoff. Our Federal Tax Group breaks down the guidelines and what they mean.

  • Dual-class structure
  • Debt
  • Delayed transfers

Read the full advisory here.

Federal Tax ADVISORY: Partial Worthlessness

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Don’t overlook claiming a deduction for partial worthlessness. Our Federal Tax Group provides a refresher on this useful tool.

  • Cross-border or brother-sister debt
  • A hard pill to swallow
  • Ordinary loss

Read the full advisory here.

Federal Tax ADVISORY: Taxpayer Wish List

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The Treasury is open for business to change tax rules to ease your compliance burdens. Our Federal Tax Group points out a few regulations that could use some updating. Reduce red tape Regulations can ease the burden What's on your list? Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Fourth Circuit Economic Substance Doctrine

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The Tax Court takes on the Fourth Circuit's version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward. The Tax Court said no The peculiar things about the opinion The takeaway Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Mutual Company Reorganizations

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Our Federal Tax Group warns that voting stock can pop up in unexpected forms, even in bank mergers.
• Mutual corporation mergers
• Voting rights as continuing equity
• The value of voting interests

Read the full advisory by clicking here. 

Federal Tax ADVISORY: A Niche Tax: The Firearms Taxes

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Our Federal Tax Group offers a rundown of the sometimes confusing laws governing firearms taxes not administered by the IRS.

  • Manufacturers excise tax
  • National Firearms Act taxes
  • Gun Control Act fees

Read the full advisory by clicking here.

Federal Tax ADVISORY: Predecessor and Successor Regulations

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There are still many questions about the meaning of the Treasury’s new regulations applying Section 355(e) to predecessors and successors. Our Federal Tax Group examines the answers we do have and what they mean for practitioners.

Read the full advisory here. 

Federal Tax Advisory: Stock Dividend Foot Faults

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Beware of the unexpected application of Section 305 to your stock distributions. Our Federal Tax Group serves up examples of useful tools to use.

Read the full advisory by clicking here.