Corporate Taxes, Appeals, Internal Revenue Code (IRC)

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

Jones Day on 12/14/2020

A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

District Court Addresses “Straddle Year” Treatment for Federal Income Tax in Bankruptcy

Patterson Belknap Webb & Tyler LLP on 8/10/2020

In an appeal of a bankruptcy court’s decision, a district court judge recently addressed the treatment of the “straddle year” for federal income tax under the Bankruptcy Code, which “does not appear to have been decided by...more

Altera: Ninth Circuit Reverses US Tax Court and Holds that Treasury Regulation Allocating Stock-Based Compensation Expenses Is...

A&O Shearman on 7/31/2018

On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

Foley & Lardner LLP on 3/15/2017

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

Coblentz Patch Duffy & Bass on 10/12/2016

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Corporate Taxes › Appeals › Internal Revenue Code (IRC)

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

District Court Addresses “Straddle Year” Treatment for Federal Income Tax in Bankruptcy

Altera: Ninth Circuit Reverses US Tax Court and Holds that Treasury Regulation Allocating Stock-Based Compensation Expenses Is...

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

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