Alston & Bird Tax Blog

Federal Tax Advisory: PPL and a Wealth Tax/New Companion to the 338(h)(10) Election

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This advisory discusses the Supreme Court’s decision PPL Corporation and Subsidiaries v. Commissioner, as well as the Treasury’s finalization of regulations under Section 336(e) proposed in 2008.

The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/fed-tax-ppl-wealth-tax  

Written by Jack Cummings, Partner, Tax | Alston & Bird LLP

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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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About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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