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Alston & Bird LLP Durham, NC Document Search Results (13) Show: results per page Sort by:  | Hobby Losses and Movies: Lee and William Storey v. CIR, T.C. Memo. 2012-115 (4/19/2012)
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article May 1, 2012, previously published on May 1, 2012 This new Tax Court decision allows a lawyer to avoid the hobby loss rule and currently deduct the costs of making a documentary movie that might be said to be “for fun,” and interprets for the first time Section 181 (enacted in 2004), which permits deduction rather than capitalization...
| | Closely Held Section 305 Issues
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article March 5, 2012, previously published on March 1, 2012 Section 305 is an antique weapon that mostly misfires. Its roots go back to the very beginnings of the income tax, when the courts were trying to figure out what was income. Stock distributions caused problems because they had value and looked like income, but everyone understood that a pro rata...
| | Quick Peek Discovery: Salem Financial, Inc. v. United States, No. 10-192T (Claims Court Jan. 18, 2012)
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article February 2, 2012, previously published on February 1, 2012 A U.S. Court of Federal Claims judge has rejected some privilege claims and directed the taxpayer to allow the government lawyers a “quick peek” at other documents the taxpayer does not want to turn over in discovery. In the course of this opinion, most of the possible issues that can...
| | Abusive Lending and Mortgage Packaging Services Targeted in State of the Union
Michael L. Brown, Craig Carpenito, Frank A. Hirsch; Alston & Bird LLP;
Legal Alert/Article February 2, 2012, previously published on January 31, 2012 In his January 24, 2012, State of the Union address, President Barack Obama announced the creation of a new law enforcement task force targeting financial crimes. Specifically, President Obama tasked Attorney General Eric Holder Jr. with creating a special group of federal and state prosecutors to...
| | Insolvent Foreign Subsidiaries: Generic Legal Advice Memorandum AM 2011-003 (August 18, 2011)
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article January 4, 2012, previously published on January 1, 2012 GLAM 2011-003 is one of the most talked about internal IRS opinions in recent years. It addresses the check-the-box liquidation of an insolvent foreign corporation and its reformation as an insolvent partnership owing a liability to its principal partner. The GLAM builds on Rev. Rul. 2003-125,...
| | All-Cash D Regulation Amended
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article December 7, 2011, previously published on December 1, 2011 On November 18, 2011, the Treasury filed an amendment to the final regulations published in 2009 that address what is known as the all-cash D reorganization. The amendment clarifies a question about stock basis involving the so-called nominal share, which some had claimed was not clear in the 2009...
| | Global Service Company’s Co-Op?
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article November 3, 2011, previously published on November 1, 2011 LTR 201141007 rules that a domestic corporation (Finco) owned by the independent, mostly foreign, “members” of a global services company will be operated on a cooperative basis in providing treasury services to the patrons.
| | Economic Substance Doctrine Defense Plan
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article October 4, 2011, previously published on October 1, 2011 Corporations have become very concerned about “best practices” and “risk management” in the wake of the Enron scandal and the subsequent enhanced enforcement rules of government agencies and auditing rules of accountants. One way to address those concerns is for corporate...
| | Tax Reform
Jasper L. Cummings; Alston & Bird LLP;
Legal Alert/Article September 7, 2011, previously published on September 1, 2011 On August 18, 2011, the Internal Revenue Service (“IRS”) issued final regulations (“Final Regulations”) on the definition of “solid waste” and “solid waste disposal facilities” with respect to the rules regarding the financing of such facilities...
| | The United States Court of Appeals for the Federal Circuit Rules That Isolated DNA Is Patent Eligible
W. Murray Spruill, Jeffrey Sunman; Alston & Bird LLP;
Legal Alert/Article August 22, 2011, previously published on August 17, 2011 On July 29, 2011, the U.S. Court of Appeals for the Federal Circuit issued its decision in Association for Molecular Pathology v. Myriad Genetics, Inc., a case that has been closely watched by the biotechnology community. The Federal Circuit affirmed the district court’s ruling that at least...
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