2000

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Tangled Web: New Form 1099 Regulations Affect Attorneys, San Francisco Daily Journal (December 29, 2000), p. 5. Simultaneously published in Los Angeles Daily Journal (December 29, 2000), p. 7.

District Court Holds Payment Not Excludable, Damage Awards Update 3:10, Tax Analysts Taxation of Damages Discussion Group (December 18, 2001).

Disability Pensions Held Excludable, Damage Awards Update 3:10, Tax Analysts Taxation of Damages Discussion Group (December 18, 2001).

Another Tortious Interference With Business Relationship Case, Damage Awards Update 3:10, Tax Analysts Taxation of Damages Discussion Group (December 18, 2001).

Magistrate Recommends Dismissal, Damage Awards Update 3:10, Tax Analysts Taxation of Damages Discussion Group (December 18, 2001).

CPA Wins on Age Discrimination, Defamation Recovery, Damage Awards Update 3:10, Tax Analysts Taxation of Damages Discussion Group (December 18, 2001).

Consider Attorney’s Fees in Tax Treatment of Settlements, Vol. 20, No. 3, The Trial Lawyer (Winter 2000), p. 22.

Leave Section 83 Out of This Mess, Vol. 89, No. 9, Tax Notes (November 27, 2000), p. 1187.

New Proposed Form 1099 Regs: Employment Lawyers and Others Take Note, Vol. 15, No. 19, BNA Employment Discrimination Report (November 15, 2000), p. 675. Reprinted in Vol. 28, No. 11, Tax Practice (December 11, 2000), p. 328.

Lawsuit Settlements: Tax Issues for Corporate Counsel, Vol. 15, No. 43, BNA’s Corporate Counsel Weekly (November 8, 2000), p. 8.

Section 104 Viability: Still Alive and Kicking, Vol. 89, No. 4, Tax Notes (October 23, 2000), p. 524.

Legal Fees Held Constructive Dividends, Damage Awards Update 3:09, Tax Analysts Taxation of Damages Discussion Group (October 14, 2000).

More IBM Cases, Damage Awards Update 3:09, Tax Analysts Taxation of Damages Discussion Group (October 14, 2000).

Punitive Damages Held Income, Damage Awards Update 3:09, Tax Analysts Taxation of Damages Discussion Group (October 14, 2000).

Why Employment Attorneys Should Address Tax Issues in Settlement Agreements, Vol. 2000, No. 9, California Employment Law Reporter (September 2000). p. 229.

Apportioning Tort Settlement on Remand, Damage Awards Update 3:08, Tax Analysts Taxation of Damages Discussion Group (August 25, 2000).

Another Employment Dispute Results in Government Victory, Damage Awards Update 3:08, Tax Analysts Taxation of Damages Discussion Group (August 25, 2000).

Excludable Damages, Taxable Income, Or Gift?, Damage Awards Update 3:08, Tax Analysts Taxation of Damages Discussion Group (August 25, 2000).

Settlement Agreement With Trust Doesn’t Effect Generation Skipping Grandfather, Damage Awards Update 3:08, Tax Analysts Taxation of Damages Discussion Group (August 25, 2000).

Can Tax Consequences Gross Up A Settlement Or Judgment?, Damage Awards Update 3:08, Tax Analysts Taxation of Damages Discussion Group (August 25, 2000).

The Energizer Bunny Has Nothing on the Attorneys’ Fee Debate, Vol. 88, No. 8, Tax Notes (August 21, 2000), p. 1059.

Robert W. Wood Responds, Vol. 88, No. 7, Tax Notes (August 14, 2000), p. 949.

Attorney’s Fees: A Few More Observations, Vol. 88, No. 5, Tax Notes (July 31, 2000), p. 701.

Even Tax Court Itself Divided on Attorneys’ Fees Issue!, Vol. 88, No. 4, Tax Notes (July 24, 2000), p. 573.

Payments Held Alimony, Damage Awards Update 3:07, Tax Analysts Taxation of Damages Discussion Group (July 18, 2000).

Another Stock Redemption Case Expands Scope of Section 1041, Damage Awards Update 3:07, Tax Analysts Taxation of Damages Discussion Group (July 18, 2000).

Allocating Settlement Awards, Damage Awards Update 3:07, Tax Analysts Taxation of Damages Discussion Group (July 18, 2000).

A Ninth Circuit Decides Yet Another Attorney’s Fee Case, Damage Awards Update 3:07, Tax Analysts Taxation of Damages Discussion Group (July 18, 2000).

Tax-Reporting Regulation Date Delayed, Vol. 25, No. 10, The Montana Lawyer (June/July 2000), p. 44.

Tax Treatment of Attorneys’ Fees Should Be Addressed in Settlement, Vol. 68, No. 48, U.S. Law Week (June 20, 2000), p. 2755.

No Deduction for Settlement “Payment”, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

No Refund Claim in John G. Sullivan, et ux. v. United States, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Two-Thirds of Disability Benefits Excludable, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Another Alimony Case, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Back and Front Pay Subject to Tax, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Punitive Damages Taxable, Holds Eleventh Circuit, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Another Ninth Circuit Opinion on the Attorneys’ Fee Issue, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Another Tax Court Case on Attorneys’ Fees, Damage Awards Update 3:06, Tax Analysts Taxation of Damages Discussion Group (June 5, 2000).

Sometimes Hoary Cases are Better Than None, Vol. 87, No. 5, Tax Notes (May 1, 2000), p. 711.

Why Tax Treatment of Attorneys’ Fees Should be Addressed in Settlement Agreements, Vol. 14, No. 16, BNA Employment Discrimination Report (April 19, 2000), p. 546.

A Brave New Loophole, Vol. 5, No. 2, House Counsel (May – June 2000), p. 38.

Why You Should Address Tax Issues in Settlement Agreements, Vol. 23, No. 3, The Trial Lawyer: Journal of Strategy, Technique & Case Management (May – June 2000), p. 238.

State Flood Relief Payments Income, Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

Another Attorneys’ Fee Decision, This Time in the Ninth Circuit, Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

More About Representative Deborah Pryce Tax Bill, Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

Settlement Terms That Are Explicit Don’t Spell “Success”, Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

Eleventh Circuit Court of Appeals Holds Fast on Legal Fee Question, Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

Sometimes Hoary Cases are Better Than None, Vol. 87, No. 5, Tax Notes (May 1, 2000), p. 711. Reprinted in Damage Awards Update 3:05, Tax Analysts Taxation of Damages Discussion Group (May 8, 2000).

Why Tax Treatment of Attorneys’ Fees Should be Addressed in Settlement Agreements, Vol. 14, No. 16, BNA’s Employment Discrimination Report (April 19, 2000), p. 546.

Always Address Tax Issues in Settlement Agreements, Vol. 87, No. 3, Tax Notes (April 17, 2000), p. 409.

More Employment Recoveries Taxable, Damage Awards Update 3:04, Tax Analysts Taxation of Damages Discussion Group (April 7, 2000).

The Other Side of Legal Fees, Damage Awards Update 3:04, Tax Analysts Taxation of Damages Discussion Group (April 7, 2000).

Another Big Attorneys’ Fee Case On The Way, Damage Awards Update 3:04, Tax Analysts Taxation of Damages Discussion Group (April 7, 2000).

Employment Dispute Payments Income, Damage Awards Update 3:04, Tax Analysts Taxation of Damages Discussion Group (April 7, 2000).

More Alimony Disputes, Damage Awards Update 3:04, Tax Analysts Taxation of Damages Discussion Group (April 7, 2000).

Attorneys Must Report Those Payments, Vol. 25, No. 7, The Montana Lawyer (March 2000), p. 20.

Wife’s Transfer of Stock to Company Was on Behalf of Ex-Husband, Damage Awards Update 3:03, Tax Analysts Taxation of Damages Discussion Group (February 26, 2000).

Deductibility of Environmental Cleanup Costs, Damage Awards Update 3:03, Tax Analysts Taxation of Damages Discussion Group (February 26, 2000).

Fines or Penalties Ties Nondeductible, Damage Awards Update 3:02, Tax Analysts Taxation of Damages Discussion Group (January 21, 2000).

New Sixth Circuit Case Helps Taxpayer on Attorneys’ Fee Issue, Damage Awards Update 3:02, Tax Analysts Taxation of Damages Discussion Group (January 21, 2000).

Damage Award Excluded From Income In Ruling, Damage Awards Update 3:02, Tax Analysts Taxation of Damages Discussion Group (January 21, 2000).

Yet Another IBM Case, Damage Awards Update 3:02, Tax Analysts Taxation of Damages Discussion Group (January 21, 2000).

Litigation Settlements: Are They Ordinary Income or Capital Gain?, Vol. 86, No. 2, Tax Notes (January 10, 2000), p. 277.

Tenth Circuit Finds No Exclusion, Damage Awards Update 3:01, Tax Analysts Taxation of Damages Discussion Group (January 7, 2000).

Settlement Proceeds Not Excludable, Damage Awards Update 3:01, Tax Analysts Taxation of Damages Discussion Group (January 7, 2000).

The Worst Kind of Legal Fees, Damage Awards Update 3:01, Tax Analysts Taxation of Damages Discussion Group (January 7, 2000).

Another Stock Redemption Case, Damage Awards Update 3:01, Tax Analysts Taxation of Damages Discussion Group (January 7, 2000).

Contingent Fee Award to Lawyer: Taxed to Lawyer or Client?, Damage Awards Update 3:01, Tax Analysts Taxation of Damages Discussion Group (January 7, 2000).

Reporting Payments to Lawyers, Vol. 20, No. 1, California Lawyer (January 2000), p. 67.

MERGERS AND ACQUISITIONS

Poison Pills and Other Defenses, Vol. 9, No. 5, The M&A Tax Report (December 2000), p. 1.

Just What is Reasonable Compensation Anyway?, Vol. 9, No. 5, The M&A Tax Report (December 2000), p. 2.

PLI’s Massive M&A Seminar Held, Vol. 9, No. 5, The M&A Tax Report (December 2000), p. 4.

Tracking Tracking Stock, Vol. 9, No. 5, The M&A Tax Report (December 2000), p. 7.

Parachute Ruling Request Withdrawn, Vol. 9, No. 5, The M&A Tax Report (December 2000), p. 8.

Whoa! Eighth Circuit Reigns in INDOPCO for Wells Fargo, Vol. 9, No. 4, The M&A Tax Report (November 2000), p. 1.

Environmental Remediation and Asbestos Removal: More INDOPCO Trash? (Part Two), Vol. 9, No. 4, The M&A Tax Report (November 2000), p. 1.

Additional Spins, Vol. 9, No. 4, The M&A Tax Report (November 2000), p. 6.

More on German Tax Reform, Vol. 9, No. 4, The M&A Tax Report (November 2000), p. 8.

Exchanging Vested Options: Is There a Golden Parachute Payment?, Vol. 9, No. 3, The M&A Tax Report (October 2000), p. 1.

1031 Exchanges of Businesses?, Vol. 9, No. 3, The M&A Tax Report (October 2000), p. 6.

Environmental Remediation and Asbestos Removal: More INDOPCO Trash? (Part One), Vol. 9, No. 3, The M&A Tax Report (October 2000), p. 7.

Altered States: New (and Not So New) Rules on Liability Assumptions, Vol. 9, No. 2, The M&A Tax Report (September 2000), p. 2.

U.S./U.K. Acquisitions: Basic Differences, Vol. 9, No. 2, The M&A Tax Report (September 2000), p. 4.

INDOPCO Applies to REIT IPO, Vol. 9, No. 2, The M&A Tax Report (September 2000), p. 7.

Massive German Tax Overhaul, Vol. 9, No. 1, The M&A Tax Report (August 2000), p. 1.

Spin offs in the News, Vol. 9, No. 1, The M&A Tax Report (August 2000), p. 1.

Tracking Stock Not Dead Yet, Vol. 9, No. 1, The M&A Tax Report (August 2000), p. 7.

More Spins in the News, Vol. 8, No. 12, The M&A Tax Report (July 2000), p. 1.

Final Regulations on Solely for Voting Stock Reverse Service Position, Vol. 8, No. 12, The M&A Tax Report (July 2000), p. 6.

Excessive Compensation?, Vol. 8, No. 11, The M&A Tax Report (June 2000), p. 1.

New Regs on Stock for Property Exchanges, Vol. 8, No. 11, The M&A Tax Report (June 2000), p. 6.

Installment Repeal Guidance Provided, Vol. 8, No. 11, The M&A Tax Report (June 2000), p. 6.

Deductions on Stock Buyback’s (Part II), Vol. 8, No. 10, The M&A Tax Report (May 2000), p. 5.

Spins: Ever Present, Vol. 8, No. 10, The M&A Tax Report (May 2000), p. 7.

Revenue Rulings Questions Statutory Mergers, Vol. 8, No. 9, The M&A Tax Report (April 2000), p. 1.

Golden Parachutes Land in Europe, Vol. 8, No. 9, The M&A Tax Report (April 2000), p. 1.

Small Deals Suffer Under New Provision, Vol. 8, No. 9, The M&A Tax Report (April 2000), p. 5.

Foreign Corporation Restructuring Regs Published, Vol. 8, No. 9, The M&A Tax Report (April 2000), p. 6.

Deduction on Stock Buyback’s (Part I), Vol. 8, No. 9, The M&A Tax Report (April 2000), p. 7.

More Spins and Spin Doctoring, Vol. 8, No. 8, The M&A Tax Report (March 2000), p. 6.

Tax Law Effect on Deals? You Bet!, Vol. 8, No. 7, The M&A Tax Report (February 2000), p. 1.

Further Spin off Thoughts, This Time Dun & Bradstreet!, Vol. 8, No. 7, The M&A Tax Report (February 2000), p. 5.

Don’t Forget About Pooling, Vol. 8, No. 7, The M&A Tax Report (February 2000), p. 7.

New Continuity of Interest Ruling, Vol. 8, No. 7, The M&A Tax Report (February 2000), p. 7.

Pooling Perambulations: Lock-Up Options and Termination Fees, Vol. 8, No. 6, The M&A Tax Report (January 2000), p. 6.

Spinoff Business Purpose: Two is Better Than One, Vol. 8, No. 6, The M&A Tax Report (January 2000), p. 7.

MISCELLANEOUS

Casualty Losses in All Their Guises: But What is Deductible?, Vol. 8, No. 7, Real Estate Tax Digest (July 2000), p. 249.

More Praise for Lee Sheppard, Vol. 87, No. 7, Tax Notes (May 15, 2000), p. 1007.

Trusts, Unlawful Detainers, and Reuniting Families, Vol. 20, No. 4, California Lawyer (April 2000), p. 31.

Consider Charitable Contributions of Real Estate, Vol. 18, No. 2, Real Estate Tax Digest (February 2000), p. 69.

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