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Articles
1-96 out of 96 article(s)
| Title |
Author |
Type |
Date |
Words |
| The Taxation of Partial Demerger. |
Westerlund, Gunnar |
|
Mar 5, 2007 |
888 |
| Caveat emptor: stock acquisition CERT limit on NOL use. |
Lehrer, John R. |
|
Jul 1, 2006 |
856 |
| Statutory mergers. |
Schwartzman, Randy A. |
|
May 1, 2006 |
2647 |
| Final section 355(e) plan regulations - the final chapter in the saga. |
Zarlenga, Lisa M. |
|
Nov 1, 2005 |
10825 |
| U.S. Leveraged Buyouts of Canadian Targets: Effective Structuring Isn't Just for Billion-Dollar Deals. |
|
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Sep 6, 2005 |
1897 |
| Expansion of A reorg. provisions. |
Schwartzman, Randy A. |
|
May 1, 2005 |
1301 |
| International Mergers & Acquisitions: Objectives, Strategies, Issues and Obstacles. |
|
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Apr 22, 2005 |
4292 |
| Tax Incentives Now Apply to Certain Real Estate Mergers. |
|
|
Apr 8, 2005 |
345 |
| Corporate Acquisitions in Ukraine: Financing Story. |
Orlov, Mykola |
|
Apr 7, 2005 |
1540 |
| Taxation of Corporate Transactions in Lithuania: Practical Approach. |
|
|
Feb 21, 2005 |
2701 |
| New regulations would permit cross-border "A" reorganizations for the first time in 70 years. |
Giles, John J. |
|
Jan 1, 2005 |
7986 |
| Appeals court confirms treatment of assumed liabilities. |
Schnee, Edward J. |
|
Nov 1, 2004 |
752 |
| New rules for qualifying a transaction as a statutory merger or consolidation under section 368(a)(1)(A) of the Internal Revenue Code. |
Fienberg, Jeffrey B. |
|
Oct 1, 2004 |
4029 |
| Basis studies are given red flags Revenue Procedure 81-70: past, present and future. |
Keppler, Juliane Laura |
|
Jul 1, 2004 |
2369 |
| Getting Out Without Selling Out: The Proposed Partnership Merger and Division Regulations. |
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|
Jun 2, 2004 |
7310 |
| Corporate acquisition expenses. |
Schnee, Edward J. |
|
Mar 1, 2004 |
964 |
| Tax Treatment of Reorganization Costs. |
Silverman, Mark J.; Weinstein, Andrew J. |
|
Jan 22, 2004 |
6046 |
| Deducting acquisition costs incurred by a shareholder, but paid by the corporation. |
Yecies, Mark |
|
Jan 1, 2004 |
1074 |
| Is it feasible to plan an acquisition of a German business on the assumption of being able to obtain over time a German deduction for the costs of acquisition? |
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Oct 22, 2003 |
376 |
| Internal Revenue Service Issues Guidance Affecting the Qualification of Multi-Step Merger Transactions as Tax-Free Reorganizations. |
Stein, Larry; Genender, Ana |
|
Oct 21, 2003 |
2162 |
| New Tax Shelter Reporting Requirements May Apply To Non-Abusive Transactions - What Borrowers And M&A Parties Must Know. |
|
|
Sep 3, 2003 |
1108 |
| 15-year amortization for covenant not to compete in redemption acquisition. |
O'Driscoll, David |
|
Aug 1, 2003 |
723 |
| Taxation of pending claims: how to handle liabilities when selling or restructuring a business. |
Maples, Larry |
|
May 1, 2003 |
3840 |
| Expansion vs. acquisition of an active trade or business for sec. 355 purposes. |
Packard, Pamela |
|
May 1, 2003 |
905 |
| Temp. Regs. on mergers involving disregarded entities. |
Packard, Pamela |
|
May 1, 2003 |
714 |
| Merger of target into acquiring corporation's SMLLC is an A reorganization. (Corporations & Shareholders). |
Lerman, Jerry L. |
|
Apr 1, 2003 |
1152 |
| The IRS reviews revenue procedure 81-70: the stakes for taxpayers are high. |
Keppler, Juliane Laura |
|
Mar 1, 2003 |
1544 |
| Tax issues for foreign acquisitions: a tax attorney outlines the benefits and challenges of specific tax code treatments involving overseas buyers and sellers. (International Taxation). |
Epstein, Stephen J. |
|
Mar 1, 2003 |
897 |
| Using A and C reorganizations in restructurings. |
Walkauskas, Gregory W. |
|
Oct 1, 2002 |
6027 |
| Revised Temp. Regs. may ease anti-Morris Trust rule effects. (Corporations & Shareholders). |
Hetzer, B. Todd |
|
Sep 1, 2002 |
1409 |
| Employee compensation attributable to acquisitions. |
Packard, Pamela |
|
May 1, 2002 |
706 |
| Certain mergers involving disregarded entities qualify as a reorganizations. |
Goldberg, Michael J. |
|
Feb 1, 2002 |
548 |
| 228. Clarification Of Loss Utilisation Directive. |
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|
Jul 20, 2001 |
1241 |
| Final regs. under secs. 338 and 1060 reflect significant changes. |
Zarzar, Robert |
|
Jul 1, 2001 |
1018 |
| Merger qualifies as tax-free reorganization, despite surviving corporation's immediate sale of assets. |
Fiore, Nicholas J. |
|
Jul 1, 2001 |
865 |
| Partnership mergers and divisions. |
Lerman, Jerry L. |
|
Apr 1, 2001 |
1431 |
| Capitalization requirement in Wells Fargo reversed. |
Sair, Edward A. |
|
Mar 1, 2001 |
1234 |
| COBE in Statutory Mergers. |
Joseph, Shibu M. |
|
Feb 1, 2001 |
608 |
| Merger Undertaken to Qualify for S Election Qualifies as F Reorganization. |
Weinberger, Mark |
|
Jan 1, 2001 |
394 |
| Salary expenses associated with bank acquisition are deductible. |
Weinberger, Mark |
|
Jan 1, 2001 |
820 |
| Merger and division prop. regs. |
Heller, Kenneth H. |
|
Dec 1, 2000 |
11801 |
| Merger integration: include a tax strategy to make a good deal better. |
|
|
Dec 1, 2000 |
487 |
| Corporate acquisition issues. |
Lane, Joe |
|
Oct 1, 2000 |
675 |
| Mergers involving disregarded entities. |
O'Connell, Frank J., Jr. |
|
Sep 1, 2000 |
938 |
| Distinctions between state law mergers and tax-free reorganizations. |
Harrison, Erich C. |
|
May 1, 2000 |
686 |
| IRS clarifies applicability of sec. 195 to business acquisitions. |
Thornton, David A. |
|
Sep 1, 1999 |
1500 |
| Golden parachute payments. |
Powers, Kevin F. |
|
Sep 1, 1999 |
2480 |
| Buying or selling a member of a consolidated group. |
Pellervo, Patricia W. |
|
Jul 1, 1999 |
16185 |
| Recent developments for using target's NOLs. |
Friedel, David |
|
Jul 1, 1999 |
955 |
| Time is short for spin-offs. |
Willens, Robert |
|
Jul 1, 1998 |
393 |
| Tax aspects of acquisitions in Germany. |
Ditsch, Stefan |
|
Jul 1, 1998 |
1219 |
| Complexities in the consolidated return reverse acquisition rules. |
Prettyman, James |
|
Jul 1, 1998 |
880 |
| Deducting equity-based and deferred compensation after a reorg. or employee transfer. |
Sollee, Will |
|
Jul 1, 1998 |
2044 |
| The direction of a merger: pitfalls and opportunities. |
Kelloway, Lisa |
|
Jun 1, 1998 |
1508 |
| Mergers of entities and nonentities: the shape of things to come? |
Liquerman, Robert |
|
Jun 1, 1998 |
651 |
| Reflections on the new COBE regs. |
Bloom, Gilbert D. |
|
Jun 1, 1998 |
1104 |
| Securities exchanges incident to B reorgs. |
Eisenberg, Andrew M. |
|
Jun 1, 1998 |
1041 |
| TRA '97 and Sec. 355. |
Geracimos, John |
|
Jun 1, 1998 |
653 |
| Deducting severance payments. |
|
Brief Article |
Nov 1, 1997 |
337 |
| New employment tax reporting procedures in business acquisitions. |
Doyle, Mary B. |
|
Nov 1, 1997 |
808 |
| Deducting your hostile takeover battles. |
Hollingsworth, Tracy |
Brief Article |
Oct 1, 1997 |
292 |
| Downsizing costs. |
Willens, Robert |
Brief Article |
Aug 1, 1997 |
205 |
| Small business tax solutions. |
Bloom, Bryan E. |
|
Jul 1, 1997 |
802 |
| Waiving a target's loss carryforwards - a preservation of stock basis. |
Lohnes, Timothy J. |
|
Jul 1, 1997 |
1066 |
| Transactions subsequent to a "B" reorganization. |
Bloom, Gilbert D. |
|
Jun 1, 1997 |
1606 |
| Proposed section 368 regulations (remote continuity-of-interest doctrine). (Tax Executive Institute's comments submitted to IRS on April 30, 1997). |
|
|
May 1, 1997 |
3387 |
| Proposed change to continuity-of-shareholder-interest requirement in acquisitive reorganizations. |
Luchs, Lorin D. |
|
May 1, 1997 |
583 |
| Subsequent dropdowns to partnerships in corporate reorganizations. |
Mahoney, Edward J. |
|
May 1, 1997 |
851 |
| INDOPCO and the tax treatment of reorganization costs. |
Weinstein, Andrew J. |
|
Jan 1, 1997 |
10048 |
| Determining whether boot received in an acquisitive reorganization has dividend effect. |
Ellentuck, Albert B. |
|
Dec 1, 1996 |
1461 |
| Spinoffs and mergers. |
Willens, Robert |
Brief Article |
Aug 1, 1996 |
288 |
| State tax treatment of net operating loss carryovers in corporate acquisitions. |
Faber, Peter L. |
|
Jul 1, 1996 |
13116 |
| Deducting defense expenses. |
Willens, Robert |
Brief Article |
May 1, 1996 |
284 |
| Treatment of a state law merger of S corporation into LLC. |
Starr, Samuel P. |
Brief Article |
Apr 1, 1996 |
398 |
| Determining whether boot received in an acquisitive reorganization has the effect of a dividend. |
Ellentuck, Albert B. |
|
Apr 1, 1996 |
1335 |
| Emerging post-Indopco issues: rationale and strategies. |
Clair, John J., Jr. |
|
Jul 1, 1995 |
800 |
| Resurrecting transactions to qualify under secs. 338 and 338(h)(10). |
Bloom, Gilbert D. |
|
Jun 1, 1995 |
1061 |
| Sec. 338(h)(10) - caveat target! |
Liquerman, Robert |
|
Jun 1, 1995 |
932 |
| REIT conversions and mergers with Ccorporations. |
deBree, James |
|
Mar 1, 1995 |
870 |
| Merger of parent and less-than-80% subsidiary. |
Hardman, Kevin |
Brief Article |
Mar 1, 1995 |
368 |
| Sec. 338(h)(10) elections involving S corporation targets. |
Stewart, Dave N. |
|
Feb 1, 1995 |
5696 |
| Buying an S corporation? Use a 338(h)(10) election. |
Willens, Robert |
Brief Article |
Jan 1, 1995 |
400 |
| New ruling on debt capital deductions. |
Willens, Robert |
Brief Article |
Nov 1, 1994 |
300 |
| S corporations and sec. 338(h)(10). |
Ward, David R. |
|
Sep 1, 1994 |
553 |
| Dealing with S termination when an S corporation joins an affiliated group. |
Ellentuck, Albert B. |
|
Aug 1, 1994 |
737 |
| Application of Sec. 338 to S corporations. |
Casinelli, Elio |
Brief Article |
Apr 1, 1994 |
378 |
| Treatment of property other than stock received in a merger or acquisition. |
Bresciani, Mary Ellen |
Brief Article |
Mar 1, 1994 |
382 |
| Sales/use tax considerations in asset transactions. |
Schaefer, Frank |
|
Feb 1, 1994 |
1444 |
| Investment company mergers - corporations and partnerships compared. |
Bryan, H. Houston |
|
Jan 1, 1994 |
777 |
| Government finally tells taxpayers that they can't bump and strip. |
Rainey, Steve |
|
Jun 1, 1993 |
1367 |
| After Indopco: the nature of a takeover. |
|
Brief Article |
Mar 1, 1993 |
323 |
| Built-in gain tax planning on sale of "subsidiary" stock. |
Bazan, Stan |
|
Feb 1, 1993 |
404 |
| A step up from Sec. 355? |
Haran, Robert B. |
|
Feb 1, 1993 |
639 |
| The purchase of a going concern: planning for intangibles. |
King, Jerry G.; Torres, Paul D. |
|
Mar 1, 1991 |
2022 |
| Takeover defense expenditures: deductibility not necessarily precluded by National Starch. |
Persellin, Mark B. |
|
May 1, 1990 |
5421 |
| Buying or selling a member of a consolidated group? |
Halby, Karen L. |
|
Mar 22, 1989 |
4029 |
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