1980s

TOPICS:

All articles written by Robert W. Wood (unless otherwise noted)

 

 

TAXATION OF DAMAGE AWARDS

 

The Constructive Receipt Myth, by George King, by Robert W. Wood and Marc Fishleder, Vol. 1, No. 2, Informed Consent (1988). Reprinted in Vol. 18, No. 6, California Trial Lawyers Association Forum (July/August 1988), p. 257.

Drafting Litigation Settlement Agreements to Achieve Tax Goals, Vol. 15, No. 5, Taxation for Lawyers (March/April 1987), p. 314.

Structured Settlements, Vol. 13, No. 11, Tax Management Compensation Planning Journal (November 1, 1985), p. 339. Digested in Vol. 37, No. 1, Monthly Digest of Tax Articles (October 1986), p. 52.

Structured Settlements After the 1984 TRA, Vol. 4, No. 42, Tax Management Weekly Report (October 21, 1985), p. 1399.

 

 

 

MERGERS AND ACQUISITIONS

 

Selected Private Letter Rulings, Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 4.

S Corporations Subject to Estimated Taxes Under New Rules, Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 4.

Is Acceptance Of S Election Needed Before Form 1120S Can be Filed?, Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 3.

IRS May Find Transfer Of S Corporation Stock Is Really a ‘Gift,’ Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 3.

Proposed Regulations on Passive Investment Income Come Under New Attack, Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 2.

S Corporation General Partner In Limited Partnership May Now Be In Jeopardy, Bulletin 12, Vol. 6, No. 12, S Corporations Tax Planning Alert, S Corporations (December 21, 1989), p. 1.

National Starch: Deductibility of Takeover Expenses Depends on New Distinction, Vol. 2, No. 4, Corporate Taxation (November/December 1989), p. 41.

New Private Letter Rulings, Bulletin 11, Vol. 6, No. 11, S Corporations Tax Planning Alert, S Corporations (November 16, 1989), p. 4.

More Guidance on What Constitutes a Qualified Subchapter S Trust, Bulletin 11, Vol. 6, No. 11, S Corporations Tax Planning Alert, S Corporations (November 16, 1989), p. 4.

Planning to Avoid the Guaranty Problem, Bulletin 11, Vol. 6, No. 11, S Corporations Tax Planning Alert, S Corporations (November 16, 1989), p. 1.

A Primer on the Ins and Outs of ESOPs: How to Decide If It’s the Right Option for Your Firm, Vol. 1, No. 25, BusinessWeek Newsletter for Family-Owned Business (November 10, 1989), p. 9.

S Corporation Distributions: Demystifying the Accumulated Adjustments Account and Other Issues, Vol. 2, No. 3, S Corporations Journal (Autumn 1989, p. 305.

IRS Cracks Down on Circumvention of General Utilities Repeal, Vol. 3, No. 1, Journal of Bank Taxation (Fall 1989), p. 50.

Recent Section 355 Developments Include Tax Court on ITC Recapture and New IRS Ruling Policy, Vol. 2, No. 3, Corporate Taxation (September/October 1989), p. 44.

Buying Out the Stockholder You Don’t Like Can Have a Nasty Tax Bite If You’re Not Careful, Vol. 1, No. 21, BusinessWeek Newsletter for Family-Owned Business (September 15, 1989), p. 7.

Drafting Corporate Acquisition Agreements to Minimize Tax Liability, Vol. 18, No. 1, Taxation for Lawyers (July/August 1989), p. 62.

New Regulations Impose Stringent Requirements on Divisive Reorganizations, Vol. 2, No. 4, Journal of Bank Taxation (Summer 1989), p. 44.

The Built-In Gain Tax After TAMRA, Vol. 2, No. 1, S Corporations Journal (Spring 1989), p. 39.

Planning Can Minimize Tax Burden on the Liquidation of an S Corporation, Vol. 1, No. 6 Corporate Taxation (March/April 1989), p. 41. Reprinted in Vol. 1, No. 3, Journal of Taxation of S Corporations (1989), p. 12.

Drafting Buy-Sell Agreements for S Corporations to Preserve Tax Benefits, Vol. 17, No. 5, Taxation for Lawyers (March/April 1989), p. 318.

How to Juggle the Tax Impact When Selling the Family Firm to a Bigger Company, Vol. 1, No. 8, BusinessWeek Newsletter for Family-Owned Business (March 3, 1989), p. 9.

Special Rules Come into Play When Liquidating an S Corporation, Vol. 1, No. 5, Corporate Taxation (January/February 1989), p. 34.

Consider Changing the Business Structure Now to Reduce the Tax Bite Later, Vol. 1, No. 3, BusinessWeek Newsletter for Family-Owned Business (December 1988), p. 9.

Step Transactions: CA-7 Collapses Steps into a Dividend Equivalent Redemption, Vol. 1, No. 4, Corporate Taxation (November/December 1988), p. 39.

There is Still Time to Avoid Gain Recognition Upon Liquidation by Electing S Status, Vol. 1, No. 3, Corporate Taxation (September/October 1988), p. 45.

It May Not Be Too Late to Liquidate, Vol. 1, No. 2, Corporate Taxation (July/August 1988), p. 40.

Settlement Proceeds in Securities Fraud Litigation Is Held to be Boot, Vol. 1, No. 1, Corporate Taxation (May/June 1988), p. 44.

Corporate Liquidations: Planning After Tax Reform, Vol. 1, No. 8, Tax Times (April 1987), p. 16B.

Business Purpose and Step-Transaction Doctrines, Vol. 13, No. 4, Journal of Corporate Taxation (Winter 1987), p. 377.

New Double Tax on Liquidations Can Be Avoided By Certain Corporations That Act Promptly, by Boyd A. Blackburn and Robert W. Wood, Vol. 38, No. 2, Taxation for Accountants (February 1987), p. 86. Reprinted in Vol. 15, No. 5, Taxation for Lawyers (March/April 1987), p. 308.

General Utilities Repeal: Injecting New Levies Into M&A, Vol. 21, No. 4, Mergers & Acquisitions (January/February 1987), p. 44.

Drafting P.C. Service Agreements to Avoid Personal Holding Company Problems, Vol. 15, No. 3, Taxation for Lawyers (November/December 1986), p. 188.

When Is Boot Taxable as a Dividend?, Vol. 13, No. 3, Journal of Corporate Taxation (Autumn 1986), p. 273.

Meeting the Business Purpose Test Under Section 355, Vol. 13, No. 2, Journal of Corporate Taxation (Summer 1986), p. 164.

The Solely for Voting Stock Requirement in B and C Reorganizations, Vol. 13, No. 1, Journal of Corporate Tax (Spring 1986), p. 76.

Application of the Solely for Voting Stock Requirement to a D Reorganization, Vol. 12, No. 4, Journal of Corporate Tax (Winter 1986), p. 381.

Incorporation of Professionals Still Offers Benefits, Vol. 3, Business Strategies (1985), p. 16995. Reprinted in Vol. 64, Taxes (1986), p. 38.

Continuity of Interest and Savings and Loan Mergers, Vol. 12, No. 3, Journal of Corporate Taxation (Autumn 1985), p. 289.

Distributions in D Reorganizations, Vol. 12, No. 2, Journal of Corporate Tax (Summer 1985), p. 197.

Developments in Corporate Organizations and Reorganizations: Legislative Developments; Administrative Developments; Judicial Developments, Vol. 12, No. 1, Journal of Tax (Spring 1985), p. 82.

E&P, Affiliated Groups, Departing Corporate Executives, All Affected by New Law Changes, Vol. 33, No. 3, Taxation for Accountants (September 1984), p. 178. Reprinted in Vol. 13, No. 3, Taxation for Lawyers (November/December 1984), p. 168.

Benefits of Distributions Paid or Received by Corporations Limited by New Law, Vol. 33, No. 2, Taxation for Accountants (1984), p. 70. Reprinted in Vol. 13, Taxation for Lawyers (1984), p. 68.

The Keller, Foglesong, and Pacella Cases: 482 Allocations, Assignments of Income, and New Section 269A, Vol. 10, No. 1, Journal of Corporate Taxation (Spring 1983), p. 65.

New S Corporation Rules Revised and Explained by Technical Corrections Act, Temporary Regs., by Fred B. Weil and Robert W. Wood, Vol. 30, No. 3, Taxation for Accountants (March 1983), p. 142. Simultaneously published in Vol. 11, No. 5, Taxation for Lawyers (March/April 1983), p. 272.

Subchapter S Corporations Made Simpler by New Law, But Not All Changes Are Improvements, by Fred B. Weil and Robert W. Wood, Vol. 29, No. 6, Taxation for Accountants (December 1982), p. 348. Reprinted in Vol. 11, No. 4, Taxation for Lawyers (January/February 1983), p. 196.

Incorporation Game Changed, San Francisco Barrister (November/December 1982), p.4.

Rethinking Professional Corporations After Tax Equity, by Fred B. Weil and Robert W. Wood, Report 29, Issue 54, CCH Financial and Estate Planning (November 18, 1982), p. 4. Reprinted in No. 120, CCH Professional Corporations Handbook (January 20, 1983), p. 9,009; Vol. 61, No. 3, Taxes (March 1983), p. 186; and AICPA Physicians and Dentists (1984).

Corporations Can Make a “Profit” from Contributions of Qualified Property, Vol. 29, No. 1, Taxation for Accountants (July 1982), p. 30.

The Desirability of Professional Corporations after the Economic Recovery Tax Act, Vol. 60, No. 4, Taxes (April 1982), p. 261. Reprinted in No. 112, CCH Professional Corporations Handbook (May 24, 1982), p. 8,917.

New Incentives for the Incorporation of Professionals, Vol. 1, No. 1, San Francisco Barrister (January/February 1982), p. 3.

Avoiding Personal Holding Company Income for Professional Corporations: Is It Really So Simple?, Vol. 59, No. 10, Taxes (October 1981), p. 685.

 

MISCELLANEOUS

 

Section 355 and Business Purpose, Tax Notes (June 5, 1989), p. 1285.

Service Addresses Use of Partnerships to Escape the Repeal of General Utilities, Real Estate Tax Digest (May 1989), p. 125.

Section 355 Regulations Go That Far?, Vol. 43, Tax Notes (April 10, 1989), p. 225.

New Revenue Procedure on Obtaining Partnership Classification, Real Estate Tax Digest (April 1989), p. 103.

Problems of Motives in Donating Real Estate, by Robert W. Wood and Jill S. Dodd, Vol. 16, No. 3, Journal of Real Estate Taxation (Spring 1989), p. 276. Reprinted in Vol. 6, No. 6, Connecticut Real Estate Law Journal (1989), p. 88.

The Magic of Bargain Sales, Vol. 16, No. 2, Journal of Real Estate Taxation (Winter 1989), p. 188.

Installment Sales: What’s Left for Real Estate and the Dealer-Investor Distinction Revisited, by Robert W. Wood and Jill S. Dodd, Real Estate Tax Digest (January 1989), p. 3.

The Final Substantiation Regulations, Vol. 16, No. 1, Journal of Real Estate Taxation (Fall 1988), p. 93.

Valuation of Charitable Contributions of Real Property, Vol. 15, No. 4, Journal of Real Estate Taxation (Summer 1988), p. 375.

Avoiding the Alternative Minimum Tax, Vol. 15, No. 3, Journal of Real Estate Taxation (Spring 1988), p. 288.

Exchange Agreements Should Set Time Limits and Allow for Nondesignation, Vol. 16, No. 4, Taxation for Lawyers (January/February 1988), p. 252.

Valuations of Property, Vol. 15, No. 1, Journal of Real Estate Taxation (Fall 1987), p. 94.

Making Bargain Sales, Vol. 14, No. 4, Journal of Real Estate Taxation (Summer 1987), p. 359.

Retained Mineral Interests in Land, Vol. 14, No. 2, Journal of Real Estate Taxation (Winter 1987), p. 194.

Giving Encumbered Property to Charity, Vol. 14, No. 1, Journal of Real Estate Taxation (Fall 1986), p. 91.

Drafting Deeds to Charity When Donor Retains Some Rights in the Property, Vol. 15, No. 2, Taxation for Lawyers (September/October 1986), p. 126.

Qualified Appraisal Rules, Vol. 13, No. 4, Journal of Real Estate Taxation (Summer 1986), p. 385.

Golden Parachutes Make Good Business Sense But Must Be Calculated Carefully to Minimize Taxes, Vol. 1, No. 17, BusinessWeek Newsletter for Family-Owned Business (July 14, 1989), p. 6.

Ways to Build Employee Loyalty By Letting Nonfamily Managers in on Company Growth, Vol. 1, No. 12, BusinessWeek Newsletter for Family-Owned Business (April 28, 1989), p. 7.

How to Help a Client Choose a Stock or Stock-Related Compensation Plan, Vol. 21, No. 12, Practical Accountant (December 1988), p. 84. Reprinted in Vol. 10, No. 1, WG&L Accounting News (Spring 1989), p. 1.

Three Cases for Compensating with Stock and Stock Substitutes, Vol. 12, No. 1, Directors and Boards (Fall 1987), p. 37.

Getting the Most Mileage Out of Bank T&E Deductions, Vol. 15, No. 1, Journal of Bank Taxation (Fall 1987), p. 11.

Drafting to Avoid Imposition of the Golden Parachute Rules, Vol. 13, No. 6, Taxation for Lawyers (May/June 1985), p. 380.

New Taxes Tarnish Luster of Golden Parachutes, by Fred B. Weil and Robert W. Wood, Vol. 19, Vol. 4, Mergers & Acquisitions (Winter 1985), p. 54.

Individual Charitable Deductions After the Tax Reform Act of 1984, Vol. 9, No. 1, Review of Taxation Individuals (Winter 1985), p. 88 .

Using the Section 83(b) Election for Market Value Transfers, Vol. 62, No. 8, Taxes (August 1984), p. 525.

Maximizing Miscellaneous Deductions for Professionals, by Robert W. Wood and Benjamin I. Delancey, Tax Planning for Professionals and Small Business Owners, San Francisco Bar Association (1984).

Using Life Insurance in the Professional Practice, by Robert W. Wood and James B. Ellis, Tax Planning for Professionals and Small Business Owners, San Francisco Bar Association (1984).

Breakups of Professional Practices, by Robert W. Wood and Benjamin I. Delancey, Tax Planning for Professionals and Small Business Owners, San Francisco Bar Association (1984).

Maximizing Miscellaneous Deductions for Professionals, Using Life Insurance in the Professional Practice, Tax Planning for Lawyers, Doctors and Accountants, San Francisco Bar Association (1983).

Breakups of Professional Practices, Tax Planning for Lawyers, Doctors and Accountants, San Francisco Bar Association (1983).

Deducting Entertainment, Automobile and Home Office Expenses, San Francisco Barrister (July/August 1982), p 6.

Research and Development Expenditures Under the Economic Recovery Tax Act, Vol. 59, No. 11, Taxes (November 1981), p. 777. Digested in Vol. 32, No. 9, Monthly Digest of Tax Articles (June 1982), p. 1.

Articles