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April 28, 2005 |

Formation, Reorganization. Liquidation of Insolvent Corporations

Certain liquidations, corporate formation transactions and reorganizations are ordinarily nontaxable, in the sense that neither gain nor loss is recognized by a party disposing of stock or assets in such a transaction. The IRS has recently proposed regulations that address the consequences of a transfer of assets that, after taking into account obligations assumed or taken subject to, lack net value.
9 minute read
April 17, 2002 |

Corporate Tax

T here has long been uncertainty as to the appropriate treatment by an accrual method taxpayer of an ordinary and necessary business expense producing a benefit that extends into the following tax year: for example, an annual premium for insurance coverage over a 12-month period straddling two taxable years. Can such an expense be deducted in the year it was made, or must it be capitalized and then written off over the term of the resulting asset (e.g., the insurance policy)?
9 minute read
February 13, 2002 |

Corporate Tax

S ection 355 of the Internal Revenue Code permits a corporation under certain circumstances to engage in a divisive, or "spinoff," transaction without the imposition of tax at either the corporate level (to reflect the unrealized appreciation in the assets or stock being distributed) or the shareholder level (to reflect receipt of what could otherwise be an ordinary taxable dividend).
9 minute read
April 23, 2002 |

Reviewing New Guidance in Like-Kind Exchanges

The Internal Revenue Service recently issued Revenue Procedure 2002-22, providing ruling guidelines for the tax classification of undivided fractional interests in rental real property. Although we continue to find clients to whom this comes as a surprise, section 1031 of the Internal Revenue Code prominently provides that the tax-free treatment accorded to like-kind exchanges does not apply to the exchange of partnership interests. Therefore, partnership interests cannot constitute either relinquished prop
10 minute read
MARCIA BETH PAUL, Davis Wright Tremaine LLP, New York, N.Y., for Plaintiffs-Appellees. EDWARD H. ROSENTHAL (Maura J. Wogan, Jessie F. Beeber, Cameron A. Myler, Marisa Sarig, on the brief), Frankfurt K
Publication Date: 2010-05-03
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MARCIA BETH PAUL, Davis Wright Tremaine LLP, New York, N.Y., for Plaintiffs-Appellees. EDWARD H. ROSENTHAL (Maura J. Wogan, Jessie F. Beeber, Cameron A. Myler, Marisa Sarig, on the brief),

December 24, 2007 |

Civil Actions

2 minute read
September 27, 2013 |

License Revocation Order Pursuant to Rule 1:28-2(c)

30 minute read
October 02, 2013 |

License Revocation Order Pursuant to Rule 1:28-2(c)

Notice to the bar.
30 minute read
September 28, 2009 |

Civil Actions

2 minute read
June 13, 2011 |

2010 Settlements Chart

56 minute read

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