1996

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Supreme Court Says Punitive Damages are Taxable Once and For All: But Just What is Punitive?, Vol. 7, No. 23, BNA Employment Discrimination Report (December 18, 1996), p. 763.

Supreme Court Says Punitive Damages are Taxable Once and For All: But Just What Is Punitive?, Vol. 1, No. 6, Damage Awards Update 96-6, Tax Analysts Taxation of Damages Discussion Group (December 13, 1996).

Look to the Code, But Don’t Stop There, Vol. 73, Tax Notes (December 2, 1996), p. 1117.

Historical Interest Only?, Vol. 1, No. 5, Damage Awards Update 96-5, Tax Analysts Taxation of Damages Discussion Group (November 5, 1996).

Pending Tax Court and District Court Cases, Vol. 1, No. 5, Damage Awards Update 96-5, Tax Analysts Taxation of Damages Discussion Group (November 5, 1996).

Settlement Subject to Employment Taxes?, Vol. 1, No. 5, Damage Awards Update 96-5, Tax Analysts Taxation of Damages Discussion Group (November 5, 1996).

Are Employment Settlements Subject to Employment Taxes?, Vol. 73, Tax Notes (November 4, 1996), p. 617.

High Stakes in Damages Case, No. 194, The Recorder (October 7, 1996), p. 1.

Section 104 Changes Bring Added Important to Attorneys’ Fees, Vol. 1, No. 4, Damage Awards Update 96-4, Tax Analysts Taxation of Damages Discussion Group (October 1, 1996).

Taxing Recovery, The Recorder (September 25, 1996), p. 5.

Clinton Signs Section 104 Changes Into Law, Vol. 1, No. 3, Damage Awards Update 96-3, Tax Analysts Taxation of Damages Discussion Group (August 26, 1996).

New Federal Law Radically Changes Tax Rules in Employment Litigation, Vol. 7, No. 8, BNA Employment Discrimination Report (August 21, 1996), p. 253.

New Law Radically Changes Tax Rules in Employment Litigation, Vol. 72, No. 8, Tax Notes (August 19, 1996), p. 1045. Reprinted in State Bar of California Legal Specialization Digest (Fall 1996), p. 9 and The Employee Advocate, Vol. 44 (Summer 1996), p. 81.

Conference Agreement on H.R. 3448 Affects Settlements, Vol. 1, No. 2, Damage Awards Update 96-2, Tax Analysts Taxation of Damages Discussion Group (August 12, 1996).

Pending Legislation, Vol. 1, No. 1, Damage Awards Update 96-1, Tax Analysts Taxation of Damages Discussion Group (July 29, 1996).

Employment Recoveries Proliferate, Vol. 1, No. 1, Damage Awards Update 96-1, Tax Analysts Taxation of Damages Discussion Group (July 29, 1996).

Consider Tax Treatment When Settling Cases, The Verdict (Summer 1996), p. 16.

Tax Treatment of State Law Recoveries for Wrongful Termination Remains Unclear, Vol. 6, No. 21, BNA Employment Discrimination Report (May 22, 1996), p. 705.

Even Tax Notes Isn’t Perfect (Although We Certainly Try), Vol. 71, No. 3, Tax Notes (April 15, 1996), p. 409.

Attorneys’ Fees Held to be Below the Line Deduction, Vol. 70, No. 10, Tax Notes (February 26, 1996), p. 1279.

When is Interest Taxable in a Judgment?, Vol. 70, No. 8, Tax Notes (February 19, 1996), p. 1055.

Can Attorneys’ Fees Be Deducted By Employment Discrimination Plaintiffs, Vol. 6, No. 6, BNA’s Employment Discrimination Report (February 7, 1996), p. 161. Reprinted in Vol. 13, The Employee Advocate (Spring 1996), p. 103.

A Damaging Look at Interest, The Recorder (February 1, 1996), p. 6.

 

 

 

MERGERS AND ACQUISITIONS

 

Small Business Job Protection Act Changes, Bulletin 9, Vol. 11, No. 9, S Corporations (December 11, 1996), p. 1.

Investment Interest Restrictions Can’t be Buried, Vol. 5, No. 5, The M&A Tax Report (December 1996), p. 1.

New Fort Howard Opinion, Vol. 5, No. 5, The M&A Tax Report (December 1996), p. 7

And a Few More Spins…, Vol. 5, No. 5, The M&A Tax Report (December 1996), p. 8.

‘Reasonable Compensation’ and the S Corporation, Bulletin 8, Vol. 11, No. 8, S Corporations (November 13, 1996), p. 3.

Final Regulations Deal With Disposition of Natural Resource Recapture Property by S Corporations, Bulletin 8, Vol. 11, No. 8, S Corporations (November 13, 1996), p. 3.

S Corp Allowed to Hold Foreign Subs, Bulletin 8, Vol. 11, No. 8, S Corporations (November 13, 1996), p. 2.

Determining Basis in S Stock Is Critical, Bulletin 8, Vol. 11, No. 8, S Corporations (November 13, 1996), p. 1.

Mergers and Continuity of Interest, by Robert Willens and Robert W. Wood, Vol. 5, No. 4, The M&A Tax Report (November 1996), p. 1.

Kerkorian’s Company Claims Sale, Not Redemption, Vol. 5, No. 4, The M&A Tax Report (November 1996), p. 7.

IRS Rules S Corporation Can be Acquirer in Deemed Asset Sale, Bulletin 7, Vol. 11, No. 7, S Corporations (October 9, 1996), p. 2.

ABA S Corporations Committee Submits Proposed Revenue Ruling on Partnership Arrangements to IRS, Bulletin 7, Vol. 11, No. 7, S Corporations (October 9, 1996), p. 2.

Do Taxpayers Still Worry About One Class of Stock Rule?, Bulletin 7, Vol. 11, No. 7, S Corporations (October 9, 1996), p. 1.

Reevaluate Choice of Entity After Small Business Act, Bulletin 7, Vol. 11, No. 7, S Corporations (October 9, 1996), p. 1.

Spin City, Vol. 5, No. 3, The M&A Tax Report (October 1996), p. 7.

Saving Payroll Taxes With Low Shareholder Compensation, Bulletin 6, Vol. 11, No. 6, S Corporations (September 11, 1996), p. 4.

Foreign Ownership by S Corporation OK, Bulletin 6, Vol. 11, No. 6, S Corporations (September 11, 1996), p. 4.

Timely Proof of Mailing S Elections Is Essential When It Comes To Securing S Status, Bulletin 6, Vol. 11, No. 6, S Corporations (September 11, 1996), p. 3.

No Deduction for Suspended Passive Losses, Bulletin 6, Vol. 11, No. 6, S Corporations (September 11, 1996), p. 2.

More Regulations Following S Corporation Reform?, Bulletin 6, Vol. 11, No. 6, S Corporations (September 11, 1996), p. 1.

Greenmail Held Not Deductible, Vol. 5, No. 2, The M&A Tax Report (September 1996), p. 1. Summarized in Greenmail Tax Rules Prove Costly, Vol. 8, No. 1, Bowne Review for CFOs & Investment Bankers (November 1996), p. 2.

Partnership Failure to File Penalty Is Inapplicable to S Corporations, Bulletin 5, Vol. 11, No. 5, S Corporations (August 21, 1996), p. 8.

Substantial Compliance in Election Requirements Will Occasionally Be Sufficient to IRS, Bulletin 5, Vol. 11, No. 5, S Corporations (August 21, 1996), p. 8.

Watch Out for Gain on Distribution of Promissory Notes, Bulletin 5, Vol. 11, No. 5, S Corporations (August 21, 1996), p. 7.

S Corporation Reform Passes, Bulletin 5, Vol. 11, No. 5, S Corporations (August 21, 1996), p. 1.

ESOPs and Hybrid ESOP Buyouts, by Robert Willens and Robert W. Wood, Vol. 5, No. 1, The M&A Tax Report (August 1996), p. 1.

Viacom 355 Ruling Sparks Praise and Criticism, Vol. 5, No. 1, The M&A Tax Report (August 1996), p. 1.

Proposed Regulations Treat Redemptions as Extraordinary Dividends, Vol. 5, No. 1, The M&A Tax Report (August 1996), p. 5.

Tax-Exempt Spinoffs?, Vol. 5, No. 1, The M&A Tax Report (August 1996), p. 6.

S Corporations Proliferate!, Bulletin 4, Vol. 11, No. 4, S Corporations (July 12, 1996), p. 7.

S Corporation Reform Legislation Back on Front Burner, Bulletin 4, Vol. 11, No. 4, S Corporations (July 12, 1996), p. 4.

Complaints About Paperwork Proliferate, Bulletin 4, Vol. 11, No. 4, S Corporations (July 12, 1996), p. 3.

Proposed ‘Check the Box’ Regulations, Bulletin 4, Vol. 11, No. 4, S Corporations (July 12, 1996), p. 1.

The IRS Solves the Problem of Allocating Income and Principal in a QSST, Vol. 13, No. 4, Journal of Taxation of Investments (Summer 1996), p. 297.

Spins Continue in the News, Vol. 4, No. 12, The M&A Tax Report (July 1996), p. 4.

Reasonable Compensation Attacks Continue, Bulletin 3, Vol. 11, No. 3, S Corporations (June 12, 1996), p. 6.

Distributive Share of LLC Income Not Passive Investment Income, Bulletin 3, Vol. 11, No. 3, S Corporations (June 12, 1996), p. 5.

When Is a Shareholders Not a Shareholder?, Bulletin 3, Vol. 11, No. 3, S Corporations (June 12, 1996), p. 3.

S Corporations Cannot Deduct Shareholders’ Legal Fees, Bulletin 3, Vol. 11, No. 3, S Corporations (June 12, 1996), p. 1.

Spinoff Changes Announced, Vol. 4, No. 11, The M&A Tax Report (June 1996), p. 1.

Section 355 Déjà Vu, Vol. 4, No. 11, The M&A Tax Report (June 1996), p. 6.

Do Not Forget About Reasonable Compensation Deductions, Bulletin 2, Vol. 11, No. 2, S Corporations (May 8, 1996), p. 5.

Pre-Share, Per-Day Allocation Rules Subject of Comment, Bulletin 2, Vol. 11, No. 2, S Corporations (May 8, 1996), p. 4.

Comments Needed on S Corporation Rental Real Estate Form, Bulletin 2, Vol. 11, No. 2, S Corporations (May 8, 1996), p. 3.

S Corporation Group Formed to Promote Legislation, Bulletin 2, Vol. 11, No. 2, S Corporations (May 8, 1996), p. 3.

Home Office Deduction Limitations — How They Apply To S Corporations, Bulletin 2, Vol. 11, No. 2, S Corporations (May 8, 1996), p. 1.

Big Breakup Fees Listed, Vol. 4, No. 10, The M&A Tax Report (May 1996), p. 8.

Accounting Adjustments — Phantom-Type Income?, Bulletin 1, Vol. 11, No. 1, S Corporations (April 10, 1996), p. 4.

Reducing Stock Basis on a Redemption, Bulletin 1, Vol. 11, No. 1, S Corporations (April 10, 1996), p. 4.

Supreme Court Refuses to Hear Entity Level Tax Treatment, Bulletin 1, Vol. 11, No. 1, S Corporations (April 10, 1996), p. 3.

Potential Repeal of IRC § 1374 Could Cause Effective Date Problems, Bulletin 1, Vol. 11, No. 1, S Corporations (April 10, 1996), p. 1.

Severance Payments and Other Golden and Quasi-Golden Parachutes, Vol. 4, No. 9, The M&A Tax Report (April 1996), p. 4.

Subscription Agreement Requirements Are Essential for Beneficial Shareholders, Bulletin 24, Vol. 10, No. 24, S Corporations (March 20, 1996), p. 4.

Built-In Gain Tax Repeal Is Still a Danger, Bulletin 24, Vol. 10, No. 24, S Corporations (March 20, 1996), p. 3.

Timely Filing of S Election Still Remains a Crucial Issue, Bulletin 24, Vol. 10, No. 24, S Corporations (March 20, 1996), p. 3.

IRS Requests Comments on S Election Tax Burdens, Bulletin 24, Vol. 10, No. 24, S Corporations (March 20, 1996), p. 2.

Some Banks Still Can Be S Corporations, Bulletin 24, Vol. 10, No. 24, S Corporations (March 20, 1996), p. 1.

Sale vs. Liquidation Dichotomy Invoked by Tax Court, Vol. 4, No. 8, The M&A Tax Report (March 1996), p. 1.

Avoiding Constructive Distributions, Vol. 8, No. 4, The M&A Tax Report (March 1996), p. 5.

Business Purpose Under Section 355 Expanding?, Vol. 8, No. 4, The M&A Tax Report (March 1996), p. 6.

Proposed Regulations Issued on Dispositions of Interests in Natural Resource Recapture Property by S Corporations, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 6.

Proposed Bill Permits S Corporations to Sponsor ESOPs, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 5.

Ninth Circuit decides Another Statute of Limitations Case, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 4.

Loans Can Produce Active Income When S Corporation Is in Business of Making Loans, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 3.

New Final Regulations on Cancellation of Debt Income, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 2.

Suspended S Corporation Losses Are Not Transferable, Bulletin 23, Vol. 10, No. 23, S Corporations (February 21, 1996), p. 1.

Executive Compensation Limitation Regs Finalized, Vol. 4, No. 6, The M&A Tax Report (February 1996), p. 1.

No Basis Increase for Guarantee of Loan by Shareholder, Bulletin 22, Vol. 10, No. 22, S Corporations (January 10, 1996), p. 4.

Winds of Change Die Down — Fiscal Years Look Unlikely, Bulletin 22, Vol. 10, No. 22, S Corporations (January 10, 1996), p. 4.

Massachusetts Rules S Distributions Not Taxable as Dividends, Bulletin 22, Vol. 10, No. 22, S Corporations (January 10, 1996), p. 3.

What Happens When an S Corporation Converts to C With An Initial Public Offering?, Bulletin 22, Vol. 10, No. 22, S Corporations (January 10, 1996), p. 3.

E&P Estimates for Last C Year May Be Critical, Bulletin 22, Vol. 10, No. 22, S Corporations (January 10, 1996), p. 1.

“Pearl Harbor” Proposal Targets Debt Securities, Vol. 4, No. 6, The M&A Tax Report (January 1996), p. 4.

S Corporation Mergers and Distributions: Which Rules Govern?, Vol. 4, No. 6, The M&A Tax Report (January 1996), p. 6.

MISCELLANEOUS

 

Conference Addresses Key Tax Issues in China, Vol. 13, No. 14, Tax Notes International (September 30, 1996), p. 1101.

Recent Authority Underscores Importance of Home Office Deduction, Vol. 14, No. 8, Real Estate Tax Digest (August 1996), p. 231.

Scenic, Conservation and Facade Easements, Vol. 14, No. 2, Real Estate Tax Digest (February 1996), p. 39.

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