Purchase Price Allocation Exhibit: More Than Meets the Eye?
Originally published in Tax Notes on April 21, 2025
Summary: This article explains the significant tax implications of purchase price allocations under section 1060, which are often intensely negotiated between buyers and sellers, and Vadim provides drafting tips for tax lawyer.
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Closing Down the Shop: Pitfalls and Opportunities in a Liquidation
Originally published in Tax Notes on September 13, 2021
Summary: This article examines a few common fact patterns involving a liquidation or wind-down of a corporation or a disregarded entity owned by a corporation. The form and timing of the transaction can produce surprising tax results.
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Originally published in Tax Notes on October 2, 2017
Summary: Many uncertainties surround the treatment of an insurance company’s deferred acquisition costs under two loss limitation provisions: the unified loss rules under Treas. Reg. 1.1502-36 and the built-in loss limitations of IRC Section 382(h).
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Intragroup Wars: Abusive Parents, Rebellious Subsidiaries
Originally published in Tax Notes on March 28, 2016
Summary: Bankruptcies and insolvencies often trigger disputes between members of consolidated groups regarding ownership of net operating losses, other tax attributes, and tax refunds.
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Originally published in Tax Notes on December 21, 2011.
Summary: Can a typical private equity fund “blocker” structure withstand a challenge under the “substantial economic effect” rules of IRC Section 704(b)?
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