1995

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Ninth Circuit Allows Law Firms to Deduct Costs Paid on the Client’s Behalf, General and Solo Practitioner, Vol. 7, No. 3 (Fall/Winter 1995), p. 8.

Proposed Bill on Tax Treatment of Damages Would Not Solve All of Lawyers’ Problems, BNA Employment Discrimination Report, Vol. 5, No. 16 (October 25, 1995), p. 471.

IRS Revisits Treatment of Gender and Race Discrimination Recoveries, Vol. 68, No. 13, Tax Notes (September 25, 1995), p. 1649. Reprinted in General and Solo Practitioner, Vol. 7, No. 3 (Fall/Winter 1995), p. 10.

Uncertainty About Deductibility for Law Firms of Costs Paid on Client’s Behalf, Vol. 5, No. 8, BNA Employment Discrimination Report (August 23, 1995), p. 231.

Schleier Strikes Taxpayers Three TImes, Vol. 68, Tax Notes (July 24, 1995), p. 475.

Appellate Tax Assistance: The Ninth Circuit Gets the IRS Out of a Lawyer’s Pockets for Costs Advanced On a Client’s Behalf, The Recorder (July 24, 1995), p. 8.

Taxpayers Get Struck Three Times in Supreme Court Ruling on Taxability of Age Discrimination Recoveries, Vol. 5, No. 1, BNA Employment Discrimination Report (July 5, 1995), p. 22.

Taxing Definitions for Types of Harm, The Recorder (June 27, 1995), p. 8.

Litigation as a Taxing Matter, The Recorder (June 9, 1995), p. 6.

Why You Should Consider Taxes in Settling Employment Disputes and/or Negotiating Employment Agreements, Vol. 22, No. 4, Advocate (April 1995), p. 22.

Consider Taxes in Negotiating Employment Terminations, Vol. 7, No. 2, General and Solo Practitioner (Spring 1995), p. 14.

Circuits Split Over Whether Age Discrimination Recoveries Are Excludable From Income, Vol. 7, No. 1, General and Solo Practitioner (Winter 1995), p. 10.

Tax Treatment of Litigation Payments, Vol. 24, No. 2, American Bar Association The Brief (Winter 1995), p. 53.

Way to Go! — Not, Vol. 4, No. 3, Business Law Today (January/February 1995), p. 19.

 

 

 

MERGERS AND ACQUISITIONS

 

AICPA Prepares Draft Ruling Dealing With S Corporation’s Payment of Insurance Premiums on Key Employees, Bulletin 21, Vol. 10, No. 21, S Corporations (December 13, 1995), p. 4.

S Corporation Converting to LLC, No Problem, Bulletin 21, Vol. 10, No. 21, S Corporations (December 13, 1995), p. 3.

AICPA Proposes S Corporation Regulation Changes, Bulletin 21, Vol. 10, No. 21, S Corporations (December 13, 1995), p. 3.

Shareholders of S Corporation Not Allowed Keogh Plan Deduction From Earnings, Bulletin 21, Vol. 10, No. 21, S Corporations (December 13, 1995), p. 1.

New Authorities on Deducting Environmental Costs, by Robert W. Wood and Steven K. Matthias, Vol. 4, No. 5, The M&A Tax Report (December 1995), p. 4.

Book Review: Taxation of Intangible Assets, Vol. 4, No. 5, The M&A Tax Report (December 1995), p. 7.

S Corporation Having COD Income Must Reduce Tax Attributes, Bulletin 20, Vol. 10, No. 20, S Corporations (November 8, 1995), p. 3.

No Bad Debt Between Divisions, Bulletin 20, Vol. 10, No. 20, S Corporations (November 8, 1995), p. 2.

S Corporation Is Held Not to Be the Taxpayer for Purposes of Filing Amended Returns, Bulletin 20, Vol. 10, No. 20, S Corporations (November 8, 1995), p. 1.

INDOPCO Rears Its Ugly Head, Preventing Deductions, Says Full Tax Court, Vol. 4, No. 4, The M&A Tax Report (November 1995), p. 1. Digested as Expense Write-Off Denied For a Not-So-Friendly Takeover, Vol. 7, No. 2, Bowne Review For CFOs & Investment Bankers (December 1995), p. 3.

Partnership Distribution of Stock Does Not Affect Continuity of Interest, Vol. 4, No. 4, The M&A Tax Report (November 1995), p. 1.

Redemption Borrowing Expenses Slated to be Deductible, Vol. 4, No. 4, The M&A Tax Report (November 1995), p. 6.

Payments to Cancel Stock Options and SARs on Takeover are Deductible, Vol. 4, No. 4, The M&A Tax Report (November 1995), p. 8.

S Corporations With 33 Trust Shareholders and 20 Individual Shareholders Still Meets 35 Shareholder Test!, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 5.

No Exception to Unified Audit and Litigation Provisions for Small S Corporations, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 5.

Another Case Holds That the Untaxed Portion of an IRC § 481(a) Adjustment Is Subject to Built-In Gain Tax, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 5.

Final Regs Under IRC § 1361 Define S Corporation Requirements, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 5.

Interminable Inadvertent Termination Rulings, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 4.

IRS Solves Allocation of Income Principal in a QSST, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 3.

Final Regs Under IRC § 1361 Define S Corporation Requirements, Bulletin 19, Vol. 10, No. 19, S Corporations (October 12, 1995), p. 1.

Liquidation of a Subsidiary Held to be a “Disposition” by Tax Court, Vol. 4, No. 3, The M&A Tax Report (October 1995), p. 1.

Payments After Sale of a Business: Is It Passive or Portfolio Income?, Vol. 4, No. 3, The M&A Tax Report (October 1995), p. 6.

New York University’s ‘Closely Held Business’ Tax Conference, Bulletin 18, Vol. 10, No. 18, S Corporations (September 13, 1995), p. 7.

Items In Brief, Bulletin 18, Vol. 10, No. 18, S Corporations (September 13, 1995), p. 6.

Bankruptcy Filing Held Not to Terminate S Election, Bulletin 18, Vol. 10, No. 18, S Corporations (September 13, 1995), p. 5.

When Is a Shareholder a Shareholder?, Bulletin 18, Vol. 10, No. 18, S Corporations (September 13, 1995), p. 4.

Built-In Gain Tax Triggered by IRC § 481 Adjustment According to Tax Court, Bulletin 18, Vol. 10, No. 18, S Corporations (September 13, 1995), p. 1.

Measuring Voting Power: Is It All in the Numbers?, by Robert W. Wood and Robert Willens, Vol. 4, No. 2, The M&A Tax Report (September 1995), p. 1.

Spin Count, Vol. 4, No. 2, The M&A Tax Report (September 1995), p. 4.

Check-the-Box System: How Far Will It Go?, Vol. 4, No. 2, The M&A Tax Report (September 1995), p. 6.

Work in Process Inventory Must Include Percentage of Profit for Built-In Gain Tax, Bulletin 17, Vol. 10, No. 17, S Corporations (August 9, 1995), p. 4.

Assistant Treasury Secretary Comments on S Corporation Reform Act Suggesting “Check-the-Box” Option for S Corporations, Bulletin 17, Vol. 10, No. 17, S Corporations (August 9, 1995), p. 2.

Proposed Regulations Released Regarding Allocations on Termination, Post-Termination Transition Period, and Other Issues, Bulletin 17, Vol. 10, No. 17, S Corporations (August 9, 1995), p. 1.

Chrysler Devises Platinum Parachutes: How Will They Stand Up Under Tax Laws?, Vol. 4, No. 1, The M&A Tax Report (August 1995), p. 1.

The Flap Continues Over Seagrams and DuPont, Vol. 4, No. 1, The M&A Tax Report (August 1995), p. 6.

Book Review: Taxation of Compensation and Benefits Demystifies Rules, Vol. 4, No. 1, The M&A Tax Report (August 1995), p. 7.

More on S Corporation Reform — Provisions That May Not Survive, Bulletin 16, Vol. 10, No. 16, S Corporations (July 13, 1995), p. 4.

Income From Rentals Held Not Passive Investment Income Despite Outside Management Company, Bulletin 16, Vol. 10, No. 16, S Corporations (July 13, 1995), p. 3.

Invalid Elections vs. Inadvertently Terminated Elections, Bulletin 16, Vol. 10, No. 16, S Corporations (July 13, 1995), p. 2.

New Bill Would Easy Fiscal Year Rules, Bulletin 16, Vol. 10, No. 16, S Corporations (July 13, 1995), p. 2.

Shareholder in River City Estopped From Denying S Status, Bulletin 16, Vol. 10, No. 16, S Corporations (July 13, 1995), p. 1.

Total Distribution Can Be More Than Sum of Its Parts, Vol. 28, No. 7, The Practical Accountant (July 1995), p. 32.

Spinoffs Dominate the News, Vol. 3, No. 12, The M&A Tax Report (July 1995), p. 2.

Tax Court Will Decide Weather Built-In Gain Tax Applies To Work in Process on C to S Conversion, Bulletin 15, Vol. 10, No. 15, S Corporations (June 14, 1995), p. 4.

S Reform Legislation Now Unlikely, Bulletin 15, Vol. 10, No. 15, S Corporations (June 14, 1995), p. 4.

Timber Sales Can Produce Built-In Gain Under IRC § 1374, Bulletin 15, Vol. 10, No. 15, S Corporations (June 14, 1995), p. 4.

Taxpayer’s Deductions From S Corporation Are Limited To Basis, According to Tax Court, Bulletin 15, Vol. 10, No. 15, S Corporations (June 14, 1995), p. 3.

Disproportionate Distributions Do Not Necessarily Violate One-Class-of-Stock Rule, Bulletin 15, Vol. 10, No. 15, S Corporations (June 14, 1995), p. 1.

Basis and Distributions for S Corporation Shareholders: Final Regulations Promulgated Under Sections 1367 and 1368, Vol. 22, No. 4, The Journal of Real Estate Taxation (Summer 1995), p. 343.

All the Flap Over Seagrams and DuPont, Vol. 3, No. 11, The M&A Tax Report (June 1995), p. 1.

Is Target Stock Really an Alternative to a Spinoff?, Vol. 3, No. 11, The M&A Tax Report (June 1995), p. 4.

Taxable Spinoffs May Now Carry Greater Tax Liabilities, Vol. 3, No. 11, The M&A Tax Report (June 1995), p. 6.

Reasonable Compensation Cases Continue to Proliferate, Bulletin 14, Vol. 10, No. 14, S Corporations (May 10, 1995), p. 4.

IRS Finds No Passive Investment Income in Two New Rulings, Bulletin 14, Vol. 10, No. 14, S Corporations (May 10, 1995), p. 3.

AICPA Urges Regulations to Permit Shareholders to Step Up Their Basis for Discharge of Indebtedness Income, Bulletin 14, Vol. 10, No. 14, S Corporations (May 10, 1995), p. 2.

S Corporation Fund Raising May Become Easier, Bulletin 14, Vol. 10, No. 14, S Corporations (May 10, 1995), p. 1.

Indirect Distributions in Life Insurance Company Reorganizations, Vol. 3, No. 10, The M&A Tax Report (May 1995), p. 5.

More Spins on the Drawing Board, Vol. 3, No. 10, The M&A Tax Report (May 1995), p. 6.

Basic Operation of Section 382, Vol. 3, No. 10, The M&A Tax Report (May 1995), p. 7.

Ban on S Corporation Stock Held by Charity May Be Lifted, Bulletin 13, Vol. 10, No. 13, S Corporations (April 12, 1995), p. 5.

Monitoring of Passive Income Is Necessary to Avoid Termination Problems, Bulletin 13, Vol. 10, No. 13, S Corporations (April 12, 1995), p. 4.

Unreasonable Compensation Paid to President and Sole Shareholder, Tax Court Holds, Bulletin 13, Vol. 10, No. 13, S Corporations (April 12, 1995), p. 2.

QSSTs, C Corporation E&P, Stock Acquisitions, and Excessive Passive Investment Income Are Topics of Inadvertent Termination Rulings, Bulletin 13, Vol. 10, No. 13, S Corporations (April 12, 1995), p. 1.

More Spinoffs In the Air, Vol. 3, No. 9, The M&A Tax Report (April 1995), p. 6.

ISO Spread Income Held to be “Wages”, Vol. 3, No. 9, The M&A Tax Report (April 1995), p. 7.

1031 Exchanges of Businesses Clarified, Vol. 3, No. 9, The M&A Tax Report (April 1995), p. 8.

More on Defective S Elections and Inadvertent Terminations, Bulletin 12, Vol. 10, No. 12, S Corporations (March 8, 1995), p. 4.

Revenue Ruling Requires Reduction in AAA On Stock Redemption, Bulletin 12, Vol. 10, No. 12, S Corporations (March 8, 1995), p. 3.

Fifty Percent Change in Ownership Terminated S Status, Bulletin 12, Vol. 10, No. 12, S Corporations (March 8, 1995), p. 1.

No Loss for Seagram on Conoco/DuPont Stock Swap, Vol. 3, No. 8, The M&A Tax Report (March 1995), p. 1.

Built-in Gains Regulations Finalized, Vol. 3, No. 8, The M&A Tax Report (March 1995), p. 4.

Book Review: M&A Tome Answers Many Questions, Vol. 3, No. 8, The M&A Tax Report (March 1995), p. 7.

Big Compensation Deductions May Ameliorate Built-In Gain Tax, Bulletin 11, Vol. 10, No. 11, S Corporations (February 8, 1995), p. 6.

Debt to Taxpayer Assumed by S Corporation Is Not Includable in Basis, Bulletin 11, Vol. 10, No. 11, S Corporations (February 8, 1995), p. 4.

Passive Loss Guidance Given to S Shareholders to Allay Confusion, Bulletin 11, Vol. 10, No. 11, S Corporations (February 8, 1995), p. 4.

Built-In Gains Regulations Finalized — A Look at What’s New, Bulletin 11, Vol. 10, No. 11, S Corporations (February 8, 1995), p. 1.

Final Partnership Antiabuse Regulations Issued, Slightly Softened, Vol. 3, No. 7, The M&A Tax Report (February 1995), p. 3.

Proposed Regulations Treat Basis Adjustments Following Triangular Mergers, Vol. 3, No. 7, The M&A Tax Report (February 1995), p. 8.

S Corporation Shareholders and Passive Loss Treatment Explained, Bulletin 10, Vol. 10, No. 10, S Corporations (January 11, 1995), p. 6.

Untangling S Corporation vs. Limited Liability Company Benefits, Bulletin 10, Vol. 10, No. 10, S Corporations (January 11, 1995), p. 3.

Outside Basis vs. Inside Basis, Bulletin 10, Vol. 10, No. 10, S Corporations (January 11, 1995), p. 2.

Inactive Subsidiaries Will Not Destroy S Election, Bulletin 10, Vol. 10, No. 10, S Corporations (January 11, 1995), p. 1.

More Parachute Payment Rulings, Vol. 3, No. 6, The M&A Tax Report (January 1995), p. 1.

FASB Harsh Option Cost Rule Reversed, Vol. 3, No. 6, The M&A Tax Report (January 1995), p. 5.

To Spin or Split: It’s All in the Name?, by Robert W. Wood and Robert Willens, Vol. 3, No. 6, The M&A Tax Report (January 1995), p. 6. Excerpted in Vol. 6, No. 4, Bowne Review for CFOs & Investment Bankers (February 1995), p. 2.

 

MISCELLANEOUS

 

Sales Tax on Food Depends on Who Eats It: New California Cuisine?, Vol. 69, No. 1, Tax Notes (October 2, 1995), p. 113.

Digesting the Law, The Recorder (September 18, 1995), p. 8.

Converting Residential Property to Investment Property, Vol. 13, No. 8, Real Estate Tax Digest (August 1995), p. 247.

Charitable Contributions of Land Raise Various Issues, Vol. 13, No. 2, Real Estate Tax Digest (February 1995), p. 39.

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