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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