1997

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

IRC Section 104 Cases, Other Settlement Issues, Continue to Merit Practitioners’ Attention, Vol. 9, No. 24, BNA Employment Discrimination Report (December 24, 1997), p. 844.

Sheppard Article Interests This Practitioner, Vol. 77, No. 12, Tax Notes (December 22, 1997), p. 1411.

Legislative Efforts Finally, Vol. 1, No. 17, Damage Awards Update 97-11, Tax Analysts Taxation of Damages Discussion Group (December 5, 1997).

More Section 104 Cases Test Old Law, Vol. 1, No. 17, Damage Awards Update 97-11, Tax Analysts Taxation of Damages Discussion Group (December 5, 1997).

Section 104 Cases Continue to Merit Attention, Vol. 77, No. 8, Tax Notes (November 24, 1997), p. 983.

Allocating Between Excludable Damages and Taxable Punitives, Vol. 1, No. 16, Damage Awards Update 97-10, Tax Analysts Taxation of Damages Discussion Group (November 19, 1997).

Another Termination Payment Case, Vol. 1, No. 15, Damage Awards Update 97-9, Tax Analysts Taxation of Damages Discussion Group (August 4, 1997).

Milk Producers Suit Against Banks Results in Excludable Settlement, Vol. 1, No. 15, Damage Awards Update 97-9, Tax Analysts Taxation of Damages Discussion Group (August 4, 1997).

Confusion High Over Tax Issues Surrounding Employment Recoveries, Vol. 5, No. 4, Employment Law Strategist (August 1997), p. 1.

Salt and Twitty Burgers Don’t Make a Digestable Argument, Vol. 76, Tax Notes, July 28, 1997, p. 555.

More Court Decisions Narrow Scope of Section 104, Vol. 1, No. 14, Damage Awards Update 97-8, Tax Analysts Taxation of Damages Discussion Group (July 1, 1997).

Are Damages For Liable Excludable?, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

Structured Settlements Would Be Extended to Workers’ Compensation Payments, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

More IBM Cases, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

More Age Cases, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

More State Farm Sex Discrimination Cases Resolved, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

Disability Benefits Not Excludable, Vol. 1, No. 13, Damage Awards Update 97-7, Tax Analysts Taxation of Damages Discussion Group (June 3, 1997).

More About the Wages Debate, Vol. 1, No. 12, Damage Awards Update 97-6, Tax Analysts Taxation of Damages Discussion Group (May 6, 1997).

Interest on Divorce Payments Held Taxable, Vol. 1, No. 12, Damage Awards Update 97-6, Tax Analysts Taxation of Damages Discussion Group (May 6, 1997).

Make Certain to Address Tax Issues in Settlement Agreements, Vol. 8, No. 15, BNA’s Employment Discrimination Report (April 9, 1997), p. 501.

Navigating the Maze of Workplace Winnings, Vol. 74, No. 12, Tax Notes (March 24, 1997), p. 1605. Reprinted in Vol. 23, No. 3, San Francisco Attorney (June/July 1997), p. 36. Also published in Vol. 1, No. 8, Damage Awards Update 97-2, Tax Analysts Taxation of Damages Discussion Group (January 28, 1997).

Another Gender Discrimination Case Held Taxable, Vol. 1, No. 11, Damage Awards Update 97-5, Tax Analysts Taxation of Damages Discussion Group (March 25, 1997).

General Releases Again, Or . . . Pizza Pizza!, Vol. 1, No. 10, Damage Awards Update 97-4, Tax Analysts Taxation of Damages Discussion Group (March 13, 1997).

Make Sure You Consider Tax Issues in Reaching a Settlement Agreement, Vol. 1, No. 10, Damage Awards Update 97-4, Tax Analysts Taxation of Damages Discussion Group (March 13, 1997).

Interest Characterization in Settlement Agreements, Vol. 74, No. 10, Tax Notes (March 10, 1997), p. 1337.

Congress Limits Tax-Free Settlements, California Lawyer (March 1997), p. 35.

Will Courts Import Punitive Characterization?, Vol. 74, No. 9, Tax Notes (March 3, 1997), p. 1200. Also published in Vol. 1, No. 8, Damage Awards Update 97-2, Tax Analysts Taxation of Damages Discussion Group (January 28, 1997).

Just What Are Personal Injury Damages?, Vol. 1, No. 9, Damage Awards Update 97-3, Tax Analysts Taxation of Damages Discussion Group (February 18, 1997).

Navigating the Tax Maze of Workplace Recoveries, Vol. 8, No. 7, BNA Employment Discrimination Report (February 12, 1997), p. 215. Reprinted in Vol. 46, The Employee Advocate (Winter 1997), p. 17.

Watch Out for Interest Characterization in Settlement Agreements, Vol. 1, No. 8, Damage Awards Update 97-2, Tax Analysts Taxation of Damages Discussion Group (January 28, 1997).

What Is Punitive?, The Recorder (January 15, 1997), p. 5.

Are Employment Settlements Subject to Employment Taxes?, Vol. 8, No. 1, BNA Employment Discrimination Report (January 1, 1997), p. 27. Reprinted in Vol. 46, The Employee Advocate (Winter 1997), p. 13.

Supreme Court Says Punitive Damages are Taxable Once and For All: But Just What is Punitive?, Vol. 46, The Employee Advocate (Winter 1997), p. 11.

 

 

MERGERS AND ACQUISITIONS

Swallowing the Anti-Seagrams Provisions, Vol. 6, No. 5, The M&A Tax Report (December 1997), p. 1.

Guidance on the Anti-Morris Trust Provision, Vol. 6, No. 5, The M&A Tax Report (December 1997), p. 6.

Disputes Still Scrappy Over Takeover Costs, Vol. 6, No. 5, The M&A Tax Report (December 1997), p. 8.

Amended Spinoff Law: How Bad Is It?, Vol. 6, No. 3, The M&A Tax Report (October 1997), p. 1. Summarized as Spinoff Restrictions Continue to Build, Vol. 9, No. 2, Bowne Review for CFOs & Investment Bankers (December 1997), p. 4.

Spin Count, Vol. 6, No. 3, The M&A Tax Report (October 1997), p. 7.

Extra Severance Pay Deductible Following Merger, Vol. 6, No. 2, The M&A Tax Report (September 1997), p. 6.

Hostile Takeover Insurance?, Vol. 6, No. 2, The M&A Tax Report (September 1997), p. 8.

Severance Payments Deductible After Acquisition, Vol. 5, No. 12, The M&A Tax Report (July 1997), p. 1.

New M&A Publication Begun, Vol. 5, No. 12, The M&A Tax Report (July 1997), p. 8.

General Utilities Repeal and Charitable Contributions, Vol. 5, No. 11, The M&A Tax Report (June 1997), p. 1.

Restoration of Triggered Gain from Deferred Intercompany Transaction, Vol. 5, No. 11, The M&A Tax Report (June 1997), p. 4.

No Ownership Change Under Golden Parachute Rules, Vol. 5, No. 11, The M&A Tax Report (June 1997), p. 6.

Spinoff Rulings; Morris Trust Repeal?, Vol. 5, No. 10, The M&A Tax Report (May 1997), p. 1.

Passive Investment Income Still a Problem, Bulletin 13, S Corporations (April 1997).

Redemption Proceeds Allocable to Trust Principal, Bulletin 13, S Corporations (April 1997).

Crooks Plus Accounting Method Changes, Bulletin 13, S Corporations (April 1997).

Another Case Holds Guarantees Do Not Increase Basis, Bulletin 13, S Corporations (April 1997).

Money is Held Income, Not Capital, Bulletin 13, S Corporations (April 1997).

Investment Banker Fees Held Deductible in Pope & Talbot, Vol. 5, No. 9, The M&A Tax Report (April 1997), p. 1.

No Amortization for Covenant Not to Compete: Yes on Client List, Vol. 5, No. 9, The M&A Tax Report (April 1997), p. 1.

Dealing With the Non-Tax Aspects of Golden Parachute Payments, Vol. 5, No. 9, The M&A Tax Report (April 1997), p. 4.

Dear Meredith: More on Intangibles, Vol. 5, No. 9, The M&A Tax Report (April 1997), p. 7.

New “Check-the-Box” Form Available, Bulletin 12, S Corporations (March 1997).

Technical Corrections to Small Business Reform Provisions Already Expected, Bulletin 12, S Corporations (March 1997).

No Gain or Loss on S Corporations Restructuring, Bulletin 12, S Corporations (March 1997).

Procedures Announced for Fixing Invalid and Late S Elections, Bulletin 12, S Corporations (March 1997).

Proposed Regs on Installment Obligations and Liquidation, Vol. 5, No. 8, The M&A Tax Report (March 1997), p. 7.

Tech Advice Says S Corp Must Use Inventory Method, Bulletin 11, S Corporations (February 1997).

Another Excessive Compensation Case, Bulletin 11, S Corporations (February 1997).

Second Class of Stock: No Issue?, Bulletin 11, S Corporations (February 1997).

Refund Claims Held Not Time Barred, Bulletin 11, S Corporations (February 1997).

Final “Check-the-Box” Regulations Issued, Bulletin 11, S Corporations (February 1997).

Proposed Regulations Issued on Continuity of Interest, Vol. 5, No. 7, The M&A Tax Report (February 1997), p. 1.

Are Training Costs Exempt from INDOPCO?, Vol. 5, No. 7, The M&A Tax Report (February 1997), p. 1.

Stock Rights Connected with Reorganization Subject of Proposed Regs, Vol. 5, No. 7, The M&A Tax Report (February 1997), p. 7.

Transitional Relief From the 1986 Tax Act: Is It Still Relevant?, Bulletin 10, S Corporations (January 1997).

Carryovers From C to S Years; No Pals, Bulletin 10, S Corporations (January 1997).

Don’t Forget About Re-Elections of S Status, Bulletin 10, S Corporations (January 1997).

S Corporation Permitted Alternate Basis Recovery Method, Bulletin 10, S Corporations (January 1997).

Like-Kind Exchange Using S Corporation’s Property Held a Constructive Distribution, Bulletin 10, S Corporations (January 1997).

Allocating Fees: To Deduct or Capitalize?, Vol. 5, No. 6, The M&A Tax Report (January 1997), p. 1. Summarized as New Advice on Deducting Consent and Tender Fees, Bowne Review for CFOs and Investment Bankers (February 1997), p. 2.

MISCELLANEOUS

To Deduct or Not to Deduct, California Lawyer (November 1997), p. 28.

Draft Carefully When Making Environmental Payments, Vol. 15, No. 9, Real Estate Tax Digest (September 1997), p. 281.

More Home Office Changes Since Soliman, Vol. 24, No. 4, Journal of Real Estate Taxation (Summer 1997), p. 402.

Revisiting Spinoffs of Real Estate, Vol. 15, No. 6, Real Estate Tax Digest (June 1997), p. 183.

Timing of Charitable Contribution and Intent, Vol. 24, No. 3, Journal of Real Estate Taxation (Spring 1997), p. 323.

Don’t Toke At Tax Time, The Recorder (April 9, 1997), p. 5.

Sheppard’s Library Needs Updating, Vol. 74, Tax Notes (February 24, 1997), p. 1075.

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