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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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

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

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

Downward Stock Attribution for CFC Purposes

April 2, 2020 By Jasper L. (Jack) Cummings, Jr.

Missing piece to CARES? Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by the Tax Cuts and Jobs Act.

Restoration of Section 958(b)(4)
New Section 951B
A newly minted controlled foreign corporation (CFC) regime

Ready full advisory here. [...]Read more

Political Action Committees

March 2, 2020 By Jasper L. (Jack) Cummings, Jr.

As election year gets into full swing, we are reminded that it isn’t just the Federal Election Commission political action committees (PACs) need to worry about. Our Federal Tax Group examines the tax pitfalls for tax-exempt organizations and one worrisome IRS ruling in particular.

The layers of PAC regulation
The most important tax variable
A surprising IRS ruling against a hospital charity

Click here to read the full advisory. [...]Read more