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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