Willens on Tax

More Willens on Tax Articles

• FASB Hits the Jackpot Question

  While casinos are only a small percentage of U.S. business, an update to an accounting rule on jackpots brings a welcome degree of uniform practice to accrual accounting. May 10, 2010

• Escaping Post-Bankruptcy Tax Constraints

  When product liability claims lead to Chapter 11, the "bankruptcy exception" can protect net operating losses from Sec. 382 limitations. November 6, 2002

• More Rare than a Perfect Game?

  The convergence of tax and accounting treatment is rare, perhaps as rare as a perfect game. But a September tax court ruling was a perfect ending to the Devil Rays' season. October 25, 2002

• The IRS Can't Do That

  U.S. Tax Court sides with charitable donors, thwarts IRS attempt to tax gifts of shares associated with acquisition targets. October 16, 2002

• Share Surrender Is Meaningless

  IRS expands meaningless gesture rule, a move that will likely reduce corporate costs associated with distributions in partial liquidations. September 4, 2002

• Declaring Dividends Capital Gains

  Dividends on stock don't accrue the same way as interest on bonds, and that means that the dividends could represent ordinary income to shareholders. But there are a few rule oddities to consider. August 21, 2002

• Look-a-Like Rules Diverge

  At first glance, the IRS rules governing nonrecognition treatment of reorganizations and spinoffs look the same--but in practice, they're not. August 14, 2002

• Partnership Requirements Getting Fuzzy

  An IRS ruling released in July seems to run counter to partnership requirements laid out in a 1992 Revenue Ruling. If that's the case, will the IRS work out the kinks? July 17, 2002

• Reviving the Reverse Morris Trust

  Reverse Morris Trust transactions gain popularity on the IRS's declaration that Revenue Ruling 70-225 is obsolete and the relaxation of the 'D' reorganization requirement. July 3, 2002