Alston & Bird Tax Blog

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

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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

Don’t Forget Ruling Guidelines

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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

Federal Tax Advisory: Disaster Losses

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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