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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Tax Complications of a $1 Billion Dollar Net Operating Loss

Recently, The New York Times shared information that presidential candidate, Donald Trump, declared a loss of $916 million on his 1995 income tax returns. In response, there has been much speculation that Donald Trump may...more

Duty of Consistency Doctrine - Effective Sword for the IRS, but Not Likely a Shield for Taxpayers - Tax Update Volume 2016, Issue...

by Pepper Hamilton LLP on

Two recent cases illustrate the IRS’ ability to successfully argue that taxpayers should not benefit from their own mistakes if they result in less tax being paid. Two recent cases highlight the most current view of the...more

Good News on “Bad Boy” Guarantees – IRS Reverts to Prior Position in Recent Legal Advice Memorandum

by Mintz Levin on

On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the...more

Your daily dose of financial news The Brief – 4.21.16

by Robins Kaplan LLP on

Dealbook’s White Collar Watch gives us a legal take on the many challenges, regulatory and otherwise, facing Elizabeth Holmes’ Theranos – NYTimes... The international financial scandal du jour (the Panama Papers) is...more

The Oman Update - Official Gazette 1127

by Dentons on

Ministerial Decisions - Ministry of Commerce & Industry - Ministerial Decision No. 315/2015 Giving Effect to the Implementing Regulations of the GCC Unified Law of Anti-dumping, Countervailing Measures &...more

Secured Creditors in Section 363 Sales Be Aware -Your Proceeds May Be Used to Satisfy the Debtor’s Unpaid State Tax Liabilities

by Dechert LLP on

It is a basic feature of sales under section 363 of the U.S. Bankruptcy Code, that the purchaser takes free and clear of all claims and interests, such claims and interests attach to the proceeds of the sale in accordance...more

California’s Harley-Davidson Decision Rides over Nexus Lines

by McDermott Will & Emery on

On May 28 2015, The California Court of Appeals issued a decision in Harley-Davidson, Inc. v. Franchise Tax Board, 187 Cal.Rptr.3d 672; and it was ultimately about much more than the validity of an election within...more

New IRS Rulings Should Provide Greater Certainty for Corporate Restructurings

by McDermott Will & Emery on

On May 5, 2015, the Internal Revenue Service (IRS) issued two long-awaited rulings, Rev. Rul. 2015-09 and Rev. Rul. 2015-10, that should ease the lives of corporate tax planners. Each ruling addressed an increasingly common...more

IRS Rulings Clarify Tax Treatment of Multi-Tier Restructuring Transactions

by Latham & Watkins LLP on

By declaring a controversial ruling obsolete, the IRS removes uncertainty surrounding the tax effects of certain corporate restructuring techniques. A pair of revenue rulings the US Internal Revenue Service (IRS)...more

LIHTC exit strategies: Right-sizing the loan

by Thompson Coburn LLP on

Note: This post is part of a continuing series on the Credit Report Blog on the subject of workouts and bankruptcies involving low-income housing tax credit (LIHTC) projects...more

IRS Will Not Follow Partner COD Bankruptcy Exception Cases

by Goulston & Storrs PC on

In a new Action on Decision (AOD 2015-10), the IRS stated that it will not follow the Tax Court’s 2004 Martinez decision, which had allowed a general partner to exclude cancellation of debt (COD) income from a partnership in...more

Commercial Restructuring & Bankruptcy Alert - February 2015

by Reed Smith on

In This Issue: - Minority Holders Gain Leverage Through Recent Interpretation of Trust Indenture Act - New Jersey Joins Number of States Creating Specialty Business Courts - Credit Bid Rights Bolstered in...more

The valuation process for LIHTC projects in financial distress: Part II

by Thompson Coburn LLP on

Note: This post is part of a continuing series on the Credit Report Blog on the subject of workouts and bankruptcies involving low-income housing tax credit (LIHTC) projects....more

Section 363 Sale Order Enjoining Successor Liability Claims Not Subject to Subsequent Attack by State Agencies

by K&L Gates LLP on

A recent decision in the ongoing bankruptcy proceedings for Chrysler has reinforced the authority of a bankruptcy court to interpret its own sale orders, and where appropriate, to enforce such an order by preventing creditors...more

What are the unique dynamics of a low-income housing tax credit workout?

by Thompson Coburn LLP on

Note: This post is part of a continuing series on the Credit Report Blog on the subject of workouts and bankruptcies involving low-income housing tax credit (LIHTC) projects. ...more

Secured Creditors Can Appeal to Tax Court on Behalf of a Bankrupt

by Bennett Jones LLP on

The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured creditor can commence or continue a tax appeal on behalf of a bankrupt...more

Escaping Taxes in Bankruptcy Through S Corporations

Shareholders of financially troubled S corporations may now be able to avoid the flow-through of taxes when the S corporation or its subsidiary files bankruptcy. ...more

Supplemental Interagency Guidance on Tax Allocation Agreements

by Ballard Spahr LLP on

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

Determining Foreigners Insolvency Exception

by Bilzin Sumberg on

Can a foreign person exclude foreign-situs assets in determining insolvency exception to cancellation of indebtedness income? With the worldwide global default rate on corporate debt continuing to rise, a taxpayer’s...more

Chapter 11 and the Sales Tax Permit

by Pullman & Comley, LLC on

Effective July 1, 2013, Connecticut passed a new law providing that the state must refuse to issue or renew a sales tax permit to any person or entity that owes taxes to the state until the taxes are paid or satisfactory...more

Chapter 11 May Help Save Sales Tax Permits for Distressed Businesses

by Pullman & Comley, LLC on

Effective July 1, 2013, Connecticut passed a new law providing that the State must refuse to issue or renew a sales tax permit to any person or entity that owes taxes to the state until the taxes are paid or satisfactory...more

Equityholder's Strategy for Shifting Tax Burdens to Creditors Upheld by Third Circuit

In re Majestic Star Casino, LLC, F.3d 736 (3rd Cir. 2013), the U.S. Court of Appeals for the Third Circuit broke from other courts by holding that S corporation status (or "qualified subchapter S subsidiary" or "QSub" status)...more

Business Bankruptcies Continue to Decline

by Joel Glucksman on

Business Bankruptcies Continue to Decline by Joel R. Glucksman on August 13, 2013 Americans have been inundated as of late with news relating to several high-profile business bankruptcies, suggesting that more...more

Potential Personal Liability for Corporate Debts

by Pullman & Comley, LLC on

A business experiencing financial difficulty will typically be forced to allocate its scarce resources toward payment of only some of its creditors. In that process, it is important to keep in mind that for some types of...more

California Quarterly Update -- A Reed Smith Quarterly Update (2nd Quarter 2013)

by Reed Smith on

Welcome to the first edition of a series of quarterly updates from Reed Smith on California state tax developments. Every quarter, we will bring you legal updates and provide some insight on what taxpayers are facing in...more

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