2001

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Tax Language in Settlement Agreements: Binding or Not?, Vol. 17, No. 23, BNA Employment Discrimination Report (December 19, 2001), p. 728; Vol. 93, No. 14, Tax Notes (December 31, 2001), p. 1872.

Further Thoughts on Tax Treatment of Punitive Damages, Tax Notes (December 10, 2001) p. 1502.

Tax Treatment of Will Contest Recoveries, Tax Notes (November 26, 2001), p. 1198.

The Continuing Attorneys’ Fees Mess, Tax Notes (November 19, 2001), p. 1115.

DC Civil Rights Tax Fairness Act, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Payment Qualify as Deductible Alimony, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Jury Award For Breach of Contract Not Excludable for Former Manager, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Damages Received Under Fair Labor Standards Act Claim Includable In Income, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Wages Garnished For Back Support Included In Income, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Settlement Payments Were U.S.-Source Royalty Income, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Another Adverse Ninth Circuit Case on Attorneys’ Fees, Damage Awards Update 4:07, Tax Analysts Taxation of Damages Discussion Group (October 24, 2001).

Precise Drafting, Vol. 114, No. 195, Los Angeles Daily Journal (October 5, 2001), p. 7. Simultaneously published in San Francisco Daily Journal (October 5, 2001), p. 7.

More IRS Guidance on Taxation of Settlements, Damage Awards Update 4:06, Tax Analysts Taxation of Damages Discussion Group (September 24, 2001).

New Proposed Regulations on Stock Redemptions, Damage Awards Update 4:06, Tax Analysts Taxation of Damages Discussion Group (September 24, 2001).

Fireman’s Death Benefits Excludable From Gross Income, Damage Awards Update 4:06, Tax Analysts Taxation of Damages Discussion Group (September 24, 2001).

Another Employment Settlement Taxable, Damage Awards Update 4:06, Tax Analysts Taxation of Damages Discussion Group (September 24, 2001).

Seventh Circuit Says “No” to Attorneys’ Fee Argument, Damage Awards Update 4:06, Tax Analysts Taxation of Damages Discussion Group (September 24, 2001).

More Confusion Over 1099s, Vol. 92, No. 9, Tax Notes (August 27, 2001), p 1215.

More Confusion Over IRS Form 1099 Obligations, Vol. 17, No. 6, BNA’s Employment Discrimination Report (August 8, 2001), p. 189.

Charitable Contribution Deduction for Settlement Payment, Damage Awards Update 4:05, Tax Analysts Taxation of Damages Discussion Group (July 26, 2001).

Speaking of Divorce…Redemptions Again, Damage Awards Update 4:05, Tax Analysts Taxation of Damages Discussion Group (July 26, 2001).

Interest Income From Divorce Is Taxable, Damage Awards Update 4:05, Tax Analysts Taxation of Damages Discussion Group (July 26, 2001).

Capitalizing Legal Costs, Damage Awards Update 4:05, Tax Analysts Taxation of Damages Discussion Group (July 26, 2001).

More Cases Indicate Age Recoveries Are Taxable, Damage Awards Update 4:05, Tax Analysts Taxation of Damages Discussion Group (July 26, 2001).

Use Tax Specific Settlement Agreements: Don’t Let Courts Influence Tax Reporting, Vol. 17, No. 3, BNA’s Employment Discrimination Report (July 18, 2001), p. 102.

Food Fight Over Contingent Attorneys’ Fees, Vol. 92, No. 3, Tax Notes (July 16, 2001), p. 434.

Taxation of Damages Why Every Settlement Agreement Should Address Tax Consequences, Vol. 10, No. 4, California Tax Lawyer (Summer 2001), p. 35.

What Litigation Recoveries are Excludable as “Physical”? IRS Finally Weighs In, Vol. 10, No. 4, California Tax Lawyer (Summer 2001).

Why Every Settlement Agreement (and Verdict) Should Address Tax Consequences, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

No Deduction for Interest on Settlement, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Asbestos Wrongful Death Action Results in Excludable Amount, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Post-Judgment Interest Paid to Attorneys Held Taxable to Attorneys, Excludable to Clients, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Eleventh Circuit Weights in on Cotnam Attorneys’ Fee Issue, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Yet Another Iteration of the Greer Case, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Amidst Tax Legislation, Employment Discrimination Tax Legislation Languishes, Damage Awards Update 4:04, Tax Analysts Taxation of Damages Discussion Group (June 13, 2001).

Why Every Settlement Agreement Should Address Tax Consequences, Vol. 92, No. 3, Tax Notes (July 16, 2001), p. 405. Reprinted in Vol. 31, No. 4, Tax Practice (July 27, 2001), p. 97; The Monthly Digest of Tax Articles (March 2002), p. 36.

Uncertain Recovery, Vol. 107, No. 102, San Francisco Daily Journal (May 25, 2001), p. 5. Simultaneously published in Los Angeles Daily Journal (May 25, 2001), p. 7.

Capitalize Those Clean-Up Costs, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

Exclusion Legislation — Any Chance of Success?, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

468B Settlement Fund Ruling, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

Noxious Emissions Yielded Taxable Income, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

Disability Benefits Partially Excludable, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

Supreme Court Refuses to Hear Coady Case, Damage Awards Update 4:03, Tax Analysts Taxation of Damages Discussion Group (April 26, 2001).

Punitive Damages: Can They Be Assigned to Avoid Income?, Vol. 16, No. 17, BNA Employment Discrimination Report (April 25, 2001), p. 607. Also published in Vol. 30, No. 6, Tax Practice (May 7, 2001), p. 166; Vol. 10, No. 4, California Tax Lawyer (Summer 2001).

Another ADEA Settlement Held Taxable, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Punitive Damages — Can They Be Assigned To Avoid Income?, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Several More Divorce Disputes, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Are ADEA Damages Allocable To Backpay?, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Attorneys’ Fee Cases Continue To Be Argued, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Race Bias Settlement Not Excludable, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

Punitive Damages Treated as Recovered by Tax Court, Damage Awards Update 4:02, Tax Analysts Taxation of Damages Discussion Group (March 28, 2001).

IRS Finally Weighs In — What Litigation Recoveries are Excludable as “Physical”?, Vol. 17, No. 1, The Employee Advocate (Spring 2001), p. 90.

What’s Left of the “Physical Injury” Tax Exclusion?, Issue 22, The Witness Chair (Spring 2001), p. 4.

Tax Provisions in Settlement Agreements: Breaches and Needless Litigation, Vol. 29, No. 11, Tax Practice (March 12, 2001), p. 324. Also published in Vol. 16, No. 11, BNA Employment Discrimination Report (March 14, 2001), p. 382.

Section 104 is Alive and Kicking, Vol. 21, No. 3, California Lawyer (March 2001), p. 25.

Why You Need To Address Tax Issues in Settlement Agreements, Vol. 26, No. 7, Montana Lawyer (March 2001), p. 28.

What Litigation Recoveries Are Excludable as “Physical”?: IRS Finally Weighs in With Some Guidance in Private Letter Ruling, Vol. 16, No. 6, BNA Employment Discrimination Report (February 7, 2001), p. 195. Also published in Vol. 29, No. 8, Tax Practice (February 19, 2001), p. 230.

What Litigation Recoveries are Excludable as ‘Physical’?, Vol. 90, Tax Notes (February 12, 2001), p. 936.

Environmental Remediation Payments, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

Several Alimony Cases Decided, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

1099 Rules Delayed Again, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

Getting Physical: Damages for Assault Without “Observable Bodily Harm”, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

Effect of Foreign Taxes Not Considered, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

Postal Service Withholding of Taxes Not a Breach of Settlement Agreement, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

Punitive Damages Held Includable, Damage Awards Update 4:01, Tax Analysts Taxation of Damages Discussion Group (January 17, 2001).

MERGERS AND ACQUISITIONS

INDOPCO Coalition Weighs In, Vol. 10, No. 5, The M&A Tax Report (December 2001), p. 1.

Revisiting the Step Transaction Doctrine, Vol. 10, No. 5, The M&A Tax Report (December 2001), p. 1.

Noncompete Agreements, Vol. 10, No. 4, The M&A Tax Report (November 2001), p. 1.

Temporary Morris Trust Regs Issued, Vol. 10, No. 3, The M&A Tax Report (October 2001), p. 5.

Contingent Liability Transaction Fails Exchange Test, Vol. 10, No. 3, The M&A Tax Report (October 2001), p. 8.

Section 1.1502-20 Loss Disallowance Regulations Invalid!, Vol. 10, No. 2, The M&A Tax Report (September 2001), p. 1.

FDIC Insurance Fees Deductible, Not INDOPCOed!, Vol. 10, No. 2, The M&A Tax Report (September 2001), p. 1.

Preferred Stock Distributed in Recapitalization Held Not Taxable, Vol. 10, No. 2, The M&A Tax Report (September 2001), p. 5.

Latest Spin News, Vol. 10, No. 2, The M&A Tax Report (September 2001), p. 6.

Germany in the News Again, Vol. 10, No. 2, The M&A Tax Report (September 2001), p. 8.

Tender Offer and Merger Equals Control for Voting Stock, Vol. 10, No. 1, The M&A Tax Report (August 2001), p. 1.

Levered ESOPs: A Management Acquisition Tool, by Rod Goodwin and Robert W. Wood, Vol. 10, No. 1, The M&A Tax Report (August 2001), p. 1.

Pooling Dead Now, Vol. 10, No. 1, The M&A Tax Report (August 2001), p. 6.

FTC Enters Your Lives, Vol. 10, No. 1, The M&A Tax Report August 2001), p. 7.

Tax-Free Merger Unaffected by Later Asset Sale, Vol. 10, No. 1, The M&A Tax Report (August 2001), p. 7.

REIT Spin offs, Vol. 9, No. 12, The M&A Tax Report (July 2001), p. 1.

European Takeovers, Vol. 9, No. 12, The M&A Tax Report (July 2001), p. 6.

Amortization Covenants, Vol. 9, No. 12, The M&A Tax Report (July 2001), p. 6.

Spins and No Spins, Vol. 9, No. 12, The M&A Tax Report (July 2001), p. 7.

No Change in Ownership, Vol. 9, No. 11, The M&A Tax Report (June 2001), p. 1.

FASB’s Final Rules, Vol. 9, No. 11, The M&A Tax Report (June 2001), p. 5.

Correction and Clarification, Vol. 9, No. 11, The M&A Tax Report

(June 2001), p. 8.

Tax and Accounting Primer for Nonqualified Stock Options, Vol. 9, No. 10, The M&A Tax Report (May 2001), p. 1.

Tax and Accounting Treatment of ISOs, Vol. 9, No. 10, The M&A Tax Report (May 2001), p. 1.

To Deduct or Capitalize Option Deal Costs, Vol. 9, No. 10, The M&A Tax Report (May 2001), p. 3.

Treatment of Options in M&A Deals, Vol. 9, No. 10, The M&A Tax Report (May 2001), p. 5.

To Rule or Not to Rule: That is the Question, Vol. 9, No. 9, The M&A Tax Report (April 2001), p. 1.

Asset Allocation Regs Finalized, Vol. 9, No. 9, The M&A Tax Report (April 2001), p. 1.

Spins and Reverse Spins, Vol. 9, No. 9, The M&A Tax Report (April 2001), p. 5.

No Change in Ownership for Golden Parachute Purposes, Vol. 9, No. 9, The M&A Tax Report (April 2001), p. 7.

More on Anti-Morris Trust Regs, Vol. 9, No. 8, The M&A Tax Report (March 2001), p. 1.

Contingent Liabilities Nondeductible, Vol. 9, No. 8, The M&A Tax Report (March 2001), p. 1.

M&A Markets — Gone Awry or Anew?, Vol. 9, No. 8, The M&A Tax Report (March 2001), p. 4.

Poison Pills and Antidotes, Bowne Review for CFOs & Investment Bankers (March 2001), p 5.

New Section 355(e) Rules Save Us!, Vol. 9, No. 7, The M&A Tax Report (February 2001), p. 1.

One More Word About Tracking Stock, Vol. 9, No. 7, The M&A Tax Report (February 2001), p. 6.

A Few More Spins, Vol. 9, No. 7, The M&A Tax Report (February 2001), p. 6.

Stock Acquisitions Given Unattractive Redemption Treatment, Vol. 9, No. 6, The M&A Tax Report (January 2001), p. 1.

Holes in Golden Parachutes, Vol. 9, No. 6, The M&A Tax Report (January 2001), p. 1.

European Deals Stagnant, Vol. 9, No. 6, The M&A Tax Report (January 2001), p. 6.

MISCELLANEOUS

Roses for Tax Notes’ AMT Coverage, Vol. 92, No. 1, Tax Notes (July 2, 2001), p. 135.

AMT Critic Wasn’t Critical Enough, Vol. 91, No. 13, Tax Notes (June 11, 2001), p. 1927.

How Do You Spell R-E-L-I-E-F?, Vol. 91, No. 10, Tax Notes (May 28, 2001), p. 1631.

Charitable Contributions of Industrial/Commercial Property: Market Tax Benefits Plus Bargain Sales Revisited, Vol. 19, No. 5, Real Estate Tax Digest (May 2001), p. 15.

Exercising Stock Options: What You (and Your Clients) Need to Know Before Joining the Dot-Com World, Vol. 18, GPSolo (January/February 2001), p. 52.

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