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Jasper L. (Jack) Cummings, Jr.

About 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.

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Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences

March 23, 2021 By Jasper L. (Jack) Cummings, Jr. and Seth Buchwald

Beware of being shortsighted. Last week, our Federal Tax Group takes the long view for borrowers and their creditors seeking to use short sales to extricate themselves from nonrecourse debt. What is a short sale?Is the short sale one integrated transaction or two separate ones?Two federal court cases tell the story Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: cancellation of indebtednes, CODI, covid-19, Fifth Circuit Court of Appeals, nonrecourse debt, Section 1001, Section 108, short sales, U.S. Tax Court

Don’t Forget Ruling Guidelines

August 3, 2020 By Jasper L. (Jack) Cummings, Jr.

Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant issue”Don’t assume there isn’t an IRS ruling guideline Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: dividend, IRS, spinoffs, stock

State-Sponsored Liability Limitation Funds

July 1, 2020 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group examines an IRS letter ruling on a company’s ability to take advantage of Section 197 intangibles. What is a liability limitation fund, and how can a company receive payments?What “event” triggers payment?What advantage is gained? Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: IRS, liability limitation fund, section 197

Federal Tax Advisory: Disaster Losses

June 1, 2020 By Jasper L. (Jack) Cummings, Jr.

With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019. An introduction to Section 165(i)The expansion of Section 165(i)Expect guidance from Treasury Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal implications of the coronavirus (COVID-19). [...]Read more

Filed Under: Federal Tax Advisory Tagged With: covid-19, Section 165, Treasury

Tax Determinations in Bankruptcy

May 5, 2020 By Jasper L. (Jack) Cummings, Jr.

For the May federal tax advisory, we considers the unclear tax powers of the bankruptcy courts and how the IRS won’t take any determinations too kindly. Prepetition tax claimsThe IRS’s constitutional and statutory defensesBankruptcy court powers in the Code Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: bankruptcy courts, IRS, Prepetition Tax Claims. the Code

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