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  • IRS Rules on Contingent Debt

    Guidance issued by the IRS nixes the idea that retirement of contingent debt is tied to cancellation of indebtedness income. August 2, 2010

  • Will BP's Tax Benefit Disappear?

    Under IRS rules, BP is entitled to a deferred tax benefit for the loss it will incur related to the Deepwater Horizon drilling rig explosion. But there is more at play than tax and accounting rules. July 30, 2010

  • A Double Taxation Warning

    U.S. companies with overseas subsidiaries may want to heed the warning of an older tax case that discusses what constitutes ownership for purposes of foreign tax credits. July 26, 2010

  • Compensatory Damages Can Be Tax Deductible

    A 2010 court decision that favored the IRS over a corporate taxpayer provides useful insights for other companies making restitution payments to the government. July 19, 2010

  • When Can a Process Be Patented?

    A hedging idea has implications for other business processes, such as tax strategies. July 12, 2010

  • State Tax Credits Do Not Imperil REITs

    IRS guidance – this one related to contaminated property – underscores why a tax credit is not a factor in making a REIT tax election. July 6, 2010

  • Cutting Your Losses? Review the Accounting

    Guidance released by the IRS underscores that the spirit, not the letter, of the rule must be followed with regard to canceling long-term contracts. June 28, 2010

  • Avoiding the "Mutually Exclusive" Deal Trap

    It's important to understand what the IRS says about deal transaction costs with respect to pursuing more than one strategy. June 21, 2010

  • IRS Attacks "Blocker" Partnerships

    In May the IRS made it tougher for foreign investors to escape taxation. June 14, 2010

  • Can Warrants Be Used to Complete a Spin-Off?

    A handful of older tax cases lay the groundwork for such a move, but there are caveats. June 7, 2010

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