1999

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Awards For Attorneys Fees, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Fixed and Determinable Damage Payments, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Settlement Payments Held Capital, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Another Field Service Advice, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Another Case on Law Firm Litigation Costs — Treated As Loans, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Effective Date for Proposed Reporting Regulations Delayed, Damage Awards Update 2:13, Tax Analysts Taxation of Damages Discussion Group (November 11, 1999).

Witnesses Didn’t Like Attorney Reporting, Damage Awards Update 2:12, Tax Analysts Taxation of Damages Discussion Group (October 20, 1999).

Another IBM Case, Damage Awards Update 2:12, Tax Analysts Taxation of Damages Discussion Group (October 20, 1999).

Another Taxable Discrimination Award, Damage Awards Update 2:12, Tax Analysts Taxation of Damages Discussion Group (October 20, 1999).

Sale of Right to Receive Monthly Tort Payments Excludable, Damage Awards Update 2:12, Tax Analysts Taxation of Damages Discussion Group (October 20, 1999).

1099s, But Not This Time?, Damage Awards Update 2:12, Tax Analysts Taxation of Damages Discussion Group (October 20, 1999).

Legal Expenses Mostly Personal and Not Deductible, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

Tax Withholding on Discrimination Award, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

Disability Benefits Partly Excludable, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

Service Continues to Litigate AMT Issue on Legal Fees, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

Attorney Reporting Regs Still Controversial, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

Overact for Capital Gain Triggering Not Required!, Damage Awards Update 2:11, Tax Analysts Taxation of Damages Discussion Group (September 28, 1999).

NELA Comments on Proposed Attorney Reporting Regulations, Damage Awards Update 2:10, Tax Analysts Taxation of Damages Discussion Group (September 14, 1999).

Watch Out for Deductibility of Fees, Damage Awards Update 2:10, Tax Analysts Taxation of Damages Discussion Group (September 14, 1999).

Pryce Bill Gaining Support, Damage Awards Update 2:10, Tax Analysts Taxation of Damages Discussion Group (September 14, 1999).

More Thoughts on Taxation of Commercial Litigation Income, Tax Notes (August 16, 1999), p. 1100.

Establishing Tax Liability In Title VII, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

Another “Delay Damages” Ruling Means Interest Is Interest, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

More 104 Focus, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

Viatical Settlements, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

Another Alimony Case, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

Another IBM Case Decided — No 104 Exclusion, Damage Awards Update 2:9, Tax Analysts Taxation of Damages Discussion Group (August 5, 1999).

Taxing Punitives, Vol. 4, No. 3, House Counsel (Summer 1999), p. 38. Reprinted in Law Finance Group, www.lawfinance.com (November 5, 1999).

Payments to Attorneys Subject of Proposed Reporting Regulations, Vol. 13, No. 2, BNA Employment Discrimination Report (July 14, 1999), p. 76.

Payments Not Alimony, Damage Awards Update 2:8, Tax Analysts Taxation of Damages Discussion Group (July 13, 1999).

Employment Case Finds No Evidence of Tort Payment Nor Section 104 Exclusion, Damage Awards Update 2:8, Tax Analysts Taxation of Damages Discussion Group (July 13, 1999).

Payments Held To Be Alimony, Damage Awards Update 2:8, Tax Analysts Taxation of Damages Discussion Group (July 13, 1999).

Eleventh Circuit to Decide Attorneys’ Fee Case, Damage Awards Update 2:8, Tax Analysts Taxation of Damages Discussion Group (July 13, 1999).

Fine vs. Deductible Payment?, Damage Awards Update 2:8, Tax Analysts Taxation of Damages Discussion Group (July 13, 1999).

Ninth Circuit Considers Settlement as Discharge of Debt, Damage Awards Update 2:7, Tax Analysts Taxation of Damages Discussion Group (June 21, 1999).

Ninth Circuit to Decide Attorneys’ Fees Case, Damage Awards Update 2:7, Tax Analysts Taxation of Damages Discussion Group (June 21, 1999).

Ninth Circuit Holds Sale of Residence Doesn’t Qualify, Damage Awards Update 2:7, Tax Analysts Taxation of Damages Discussion Group (June 21, 1999).

Post-Judgment Interest Held Taxable, Damage Awards Update 2:7, Tax Analysts Taxation of Damages Discussion Group (June 21, 1999).

Tax Legislation Introduced, Damage Awards Update 2:7, Tax Analysts Taxation of Damages Discussion Group (June 21, 1999).

Settlement Payments and Capitalization, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

Field Service Advice May Contraindicate “Direct Interest in Case” by Lawyers, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

In Employment Litigation, Consider Physical Claims, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

Another Title VII Case Taxable, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

Attorneys’ Fee Netting Case on Appeal, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

Payments to Attorneys Subject of Reporting Regs, Damage Awards Update 2:6, Tax Analysts Taxation of Damages Discussion Group (May 31, 1999).

Another Section 1041 Case Involving Community Property Transfers, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Article Regards Legal Costs as Medical Expenses, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Stock Redemption Held Incident to Divorce So Within Protection of Section 1041, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Another IBM Settlement Held Taxable, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Tortious Interference Damages Held Income, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Another Title VII Recovery Held Taxable, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Portion of Settlement Attributable to Mental Anguish Held Excludable, Damage Awards Update 2:5, Tax Analysts Taxation of Damages Discussion Group (May 12, 1999).

Payment to Third Party May or May Not Be Property Settlement, Damage Awards Update 2:4, Tax Analysts Taxation of Damages Discussion Group (April 20, 1999).

Payment for Deprivation of Civil Rights Not Income, Damage Awards Update 2:4, Tax Analysts Taxation of Damages Discussion Group (April 20, 1999).

Improper Allocation of Settlement Payments, Damage Awards Update 2:4, Tax Analysts Taxation of Damages Discussion Group (April 20, 1999).

Severance Payments Held Wages, Damage Awards Update 2:4, Tax Analysts Taxation of Damages Discussion Group (April 20, 1999).

Legal Cost of Defending Against Sexual Assault Held Nondeductible, Damage Awards Update 2:4, Tax Analysts Taxation of Damages Discussion Group (April 20, 1999).

Timing of Arbitration Award, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Payment Held Not Alimony, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Settlement Payment Qualified For Pension Rollover, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Long-Term Disability Settlement Held Taxable, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Employment Lawyers Seek Repeal, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Ninth Circuit Holds Title VII Sex Bias Recoveries Taxable, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Another Prejudgment Interest Case, Damage Awards Update 2:3, Tax Analysts Taxation of Damages Discussion Group (March 11, 1999).

Settling Employers: Do You Withhold or Not?, Vol. 82, No. 13, Tax Notes (March 29, 1999), p. 2001.

Sex Discrimination Settlement Held Not Excludable, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

ERISA Settlement Held Partly Excludable Under Section 104!, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

Stock Redemption Held Nontaxable Transfer In Divorce, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

Malicious Prosecution Settlement Partly Excludable Says IRS!, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

Punitive Damages Proposal, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

Another Field Service Advice, This Time on Punitive Damages, Damage Awards Update 2:2, Tax Analysts Taxation of Damages Discussion Group (February 12, 1999).

Should Prejudgment Interest Be Taxable?, Vol. 82, No. 5, Tax Notes (February 1, 1999), p. 719.

Withholding on Awards and Settlements Redux, Vol. 82, No. 3, Tax Notes (January 18, 1999), p. 381.

Disability Benefits Excludable in Part, Vol. 2, No. 1, Damage Awards Update 2:1, Tax Analysts Taxation of Damages Discussion Group (January 7, 1999).

Tax Provisions Not Essential To Agreement, Vol. 2, No. 1, Damage Awards Update 2:1, Tax Analysts Taxation of Damages Discussion Group (January 7, 1999).

Prejudgment Interest Rears Its Held Again, Vol. 2, No. 1, Damage Awards Update 2:1, Tax Analysts Taxation of Damages Discussion Group (January 7, 1999).

Settlement For Business Reputation Held Not Per Se Personal Injury Damages, Vol. 2, No. 1, Damage Awards Update 2:1, Tax Analysts Taxation of Damages Discussion Group (January 7, 1999).

Scope of Personal Injury Tax Exclusion Still Clouded, Tax Practice (January 4, 1999), p. 12. Also published in Vol. 81, No. 13, Tax Notes (December 28, 1998), p. 1675; and in Vol. 11, No. 24, BNA Employment Discrimination Report (December 23, 1998), p. 857.

MERGERS AND ACQUISITIONS

How Much is “Substantially All?”, Vol. 8, No. 5, The M&A Tax Report (December 1999), p. 1.

Redemptions: Gaining a Capital Gain, Vol. 8, No. 5, The M&A Tax Report (December 1999), p. 1.

Recapitalization Accounting, Vol. 8, No. 5, The M&A Tax Report (December 1999), p. 4.

Book Review: The Best in M&A, Vol. 8, No. 5, The M&A Tax Report (December 1999), p. 6.

Forming and Liquidating Simpler in California, by Kathleen K. Wright and Robert W. Wood, Vol. 8, No. 4, The M&A Tax Report (November 1999), p. 1.

High Tech Mergers and Acquisitions Institute Held in Silicon Valley, Vol. 8, No. 4, The M&A Tax Report (November 1999), p. 6.

Morris Trust Regulations At Last, Part II of II, Vol. 8, No. 4, The M&A Tax Report (November 1999), p. 7.

Tracking Stock Makes New (Again), Vol. 8, No. 3, The M&A Tax Report (October 1999), p. 1.

IRS Issues Regulations Under Section 338, Vol. 8, No. 3, The M&A Tax Report (October 1999), p. 1.

Devices Under Section 355: Who, Me?, Vol. 8, No. 3, The M&A Tax Report (October 1999), p. 6.

Morris Trust Regulations at Last, Part I of II, Vol. 8, No. 3, The M&A Tax Report (October 1999), p. 7.

M&A Taxes: Voluminous System, California Law Business, Special Supplement, Vol. 112, No. 191, Los Angeles Daily Journal (October 4, 1999), p. 28. Simultaneously published in San Francisco Daily Journal (October 4, 1999), p. 28.

Advance Pricing Agreement Fees: INDOPCO Exempt!, Vol. 8, No. 2, The M&A Tax Report (September 1999), p. 1.

Stock Rights in Reorganizations: New Bells and Whistles?, Vol. 8, No. 2, The M&A Tax Report (September 1999), p. 1.

Section 269 and Tax Avoidance: Should the IRS Give Up?, Vol. 8, No. 2, The M&A Tax Report (September 1999), p. 4.

Bad “Device” Present in Cable & Wireless Deal, Vol. 8, No. 2, The M&A Tax Report (September 1999), p. 7.

Pope & Talbot’s Last Gasp, Vol. 8, No. 1, The M&A Tax Report (August 1999), p. 1.

Disqualified Debt Instruments, Vol. 8, No. 1, The M&A Tax Report (August 1999), p. 1.

Current Spins in the News, Vol. 8, No. 1, The M&A Tax Report (August 1999), p. 5.

Whither Bausch & Lomb?, Vol. 8, No. 1, The M&A Tax Report (August 1999), p. 6.

INDOPCO Hits Reorgs — What’s Deductible and What’s Not, Vol. 8, No. 1, The M&A Tax Report (August 1999), p. 7.

Spin offs and Cost Savings: Is It The Business Purpose?, Vol. 7, No. 12, The M&A Tax Report (July 1999), p. 1.

U.S. West and Global Crossing: Taxing History, Vol. 7, No. 12, The M&A Tax Report (July 1999), p. 1.

Amortizing Goodwill: FASB Still At It After All These Years, Vol. 7, No. 12, The M&A Tax Report (July 1999), p. 6.

Pooling: One More Word, Vol. 7, No. 12, The M&A Tax Report (July 1999), p. 7.

Capitalizing Plant Costs?, Vol. 7, No. 12, The M&A Tax Report (July 1999), p. 8.

‘Pooling of Interests’ Accounting to be Ousted, Vol. 7, No. 11, The M&A Tax Report (June 1999), p. 1.

IRS Embraces ‘Deductible’ Preferred, Vol. 7, No. 11, The M&A Tax Report (June 1999), p. 1.

More Acquisition Expenses to Watch Out For, Vol. 7, No. 11, The M&A Tax Report (June 1999), p. 5.

Continuity of Business Enterprise Requirement: Loved but Misunderstood?, Vol. 7, No. 11, The M&A Tax Report (June 1999), p. 7.

Retaining Stock After a Spin off, Vol 7, No. 10, The M&A Tax Report (May 1999), p. 1.

Spin Offs of Captive Companies, Vol. 7, No. 9, The M&A Tax Report (April 1999), p. 1.

Will FASB Actions Derail the M&A Train?, Vol. 7, No. 9, The M&A Tax Report (April 1999), p. 3.

Stingy Continuity of Interest Rulings, Vol. 7, No. 9, The M&A Tax Report (April 1999), p. 6.

Preacquisition Salaries Nondeductible Under INDOPCO, Vol. 7, No. 9, The M&A Tax Report (April 1999), p. 7.

Newspaper Publisher Required to Capitalize Expenses of Carrier Settlement, Vol. 7, No. 9, The M&A Tax Report (April 1999), p. 8.

Voting Power and Consolidations: The Alumax Story, Vol. 7, No. 8, The M&A Tax Report (March 1999), p. 5.

Crossing Borders: Legitimizing Outbound Reorganizations, Vol. 7, No. 8, The M&A Tax Report (March 1999), p. 6.

FASB Rules and Consolidations, Vol. 7, No. 8, The M&A Tax Report (March 1999), p. 8.

Pooling Primer for Tax Pros, Vol. 10, No. 5, Bowne Review for CFOs and Investment Bankers (March 1999), p. 7.

Spin Update, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 1.

Beware Tax Avoidance Purpose, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 1.

Covenants Not to Compete: Be Realistic, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 3.

Liquidating a Recently Acquired Subsidiary, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 4.

Section 1031: Not Just for Real Estate, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 5.

Redemption Expenses Nondeductible: Avoiding Redemption Characterization, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 7.

One More FSA: This Time, Continuity of Interest, Vol. 7, No. 7, The M&A Tax Report (February 1999), p. 8.

The Continued Controversy About Pooling Transactions, Vol. 7, No. 6, The M&A Tax Report (January 1999), p. 1.

Poison Pills and ‘Dead Hand’ Pills, Vol. 7, No. 6, The M&A Tax Report (January 1999), p. 1.

Retiring Debt After a Spin off, Vol. 7, No. 6, The M&A Tax Report (January 1999), p. 5.

Spins in the News, Vol. 7, No. 6, The M&A Tax Report (January 1999), p. 5.

Watch Out for Golden Parachute Rules in Restructuring, Vol. 7, No. 6, The M&A Tax Report (January 1999), p. 7.

How to Satisfy the Business Purpose Test for Tax-Free Spinoffs, Vol. 10, No. 3, Bowne Review for CFOs & Investment Bankers (January 1999), p. 4; abstracted from Spinoffs and the All-Important Business Purpose, Vol. 7, No. 5, The M&A Tax Report (December 1998), p. 1.

MISCELLANEOUS

Valuing Stock: Built-in Tax, Securities Laws and Other Such Blemishes, Vol. 17, No. 6, Real Estate Tax Digest (June 1999), p. 179.

Hobby or Business: Brothel-Hopping Scrutinized by IRS, Tax Notes (June 28, 1999), p. 1941.

1999 Yields Home Office Expense Deductions (Finally), Vol. 26, No. 4, Journal of Real Estate Taxation (Summer 1999), p. 326.

New LLC Book Delivers, Vol. 82, No. 15, Tax Notes (April 12, 1999), p. 303

Recent Decisions Give Valuation Discounts a Boost, Vol. 26, No. 3, Journal of Real Estate Taxation (Spring 1999), p. 224.

Home Office Deductions, Vol. 26, No. 3, Journal of Real Estate Taxation (Spring 1999), p. 253.

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