• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

Federal - Corporate Tax Planning

Tax Reform: Invitation to the Weekly Client Update from Alston & Bird

January 8, 2018 By Alston & Bird Tax Team

With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.   The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information.   [...]Read more

Filed Under: Corporate - Federal, Corporate - State, Employee Benefits, Federal - Corporate Tax Planning, Federal Tax, Partnerships, Tax Policy, Tax Reform Tagged With: corporate, employee benefits, executive compensation, health & welfare, international tax, partnerships, section 965, Tax, tax reform

Tax Change Planning

October 2, 2017 By Jasper L. (Jack) Cummings, Jr.

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

Filed Under: Federal - Corporate Tax Planning, Federal Tax, Federal Tax Advisory, Tax Policy, Tax Reform Tagged With: corporate rate, tax reform

Second Inversion Notice

November 22, 2015 By Jasper L. (Jack) Cummings, Jr.

The Treasury issued the new Notice 2015-79 to beef up the anti-inversion section 7874. It contains three rules applicable to deals closing after the Notice and two rules that are retroactive to the 2014 Notice’s effective date. Those two rules increase the potential taxability of post-inversion restructurings. The three prospective rules are the most surprising and potentially harmful to taxpayers seeking to invert. They all relate to the use of holding company structures, which are common in cross border tax planning. Holding company structure rules: If the foreign acquiring corporation [...]Read more

Filed Under: Federal - Corporate Tax Planning, International - Corporate Tax Planning, Mergers and Acquisitions Tagged With: Notice 2015-79

Déjà Vu All Over Again – The Recurring Saga of Expiring Tax Provisions

September 21, 2015 By Carolyn Smith

If you go by what Yogi Berra says, tax policy and baseball have a lot in common.  Just as we head toward the end of the regular season of baseball and hope we make it to play-offs, Congress is doing the same.  Having returned from the August recess, they are looking ahead at what they need to do to finish strong.  As for déjà vu, the atmosphere surrounding expired tax provisions is markedly similar to what it was last year around this time.  Will the result be different this year?  Maybe.  Let’s take a look at the issues and what’s happened so far. Discussions of tax reform have [...]Read more

Filed Under: Federal - Corporate Tax Planning, Federal Tax, International - Corporate Tax Planning, International - Inbound, International - Outbound, Tax Policy Tagged With: tax reform

“Nobody Loses All The Time”: Remembering Negative Precedents

March 6, 2015 By Jasper L. (Jack) Cummings, Jr.

The IRS can have a long memory when it comes to rulings and decisions against taxpayers. Even with the seemingly all-purpose economic substance doctrine in its utility belt, the IRS sometimes dusts off old precedents to attack transactions. Revenue Ruling 80-239, 1980-2 C.B. 103, and Basic, Inc. v. United States, 549 F.2d 740 (Ct. Cl. 1977) are two anti-taxpayer authorities that targeted perceived abuses that are now largely obsolete. Nevertheless, the IRS may still invoke these precedents for support in totally different situations. Taxpayers should be aware of how the IRS might use [...]Read more

Filed Under: Controversies - Federal, Corporate - Federal, Federal - Corporate Tax Planning, Federal Tax Advisory Tagged With: Basic Inc. v. United States, Corporate Tax Planning, economic substance doctrine, IRS, precedent, Rev. Rul. 80-239

  • Go to page 1
  • Go to page 2
  • Go to page 3
  • Interim pages omitted …
  • Go to page 10
  • Go to Next Page »

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?
  • California Dreaming of a Voluntary Compliance Program
  • Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care

Archives

Copyright © 2022 · Alston & Bird · All Rights Reserved. Privacy.