2002

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Estate’s Deduction Limited For Royalty Reimbursement, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

Pension Benefits Are Taxable Income Not Excluded By Section 1041, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

Payments Qualify as Deductible Alimony, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

Which Form Should Be Used For Reporting Attorneys’ Fees?, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

Guidance on Viatical Insurance Companies, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

No Deduction for Criminal Defense Legal Fees, Damage Awards Update 5:08, Tax Analysts Taxation of Damages Discussion Group (December 17, 2002).

Making Room for the Middleman: New Tax Rules for Attorneys’ Fees Go Into Effect Jan. 1, by Robert W. Wood and Jonathan R. Flora, The Recorder (December 4, 2002), p. 4.

Davenport’s Solution for the Attorney’s Fee Mess: A Capital Idea, Vol. 97, No. 7, Tax Notes (November 18, 2002), p. 969.

Settlement Payments and Their Myriad Tax Consequences, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

More Divorce Authority, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

Policemen’s Lump Sum and Retiree Bonuses Excludable, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

Punitive Damage Controversy Heating Up?, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

Settlement Payments and the Dying Spouse, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

Federal Disability Retirement: Taxable Income, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

Pension Lawsuit Settlement Payment Deductible, Damage Awards Update 5:07, Tax Analysts Taxation of Damages Discussion Group (November 6, 2002).

New (Final!) Form 1099 Reporting Regs: Attorneys’ Fee Regs in Drag?, by Robert W. Wood and Jonathan R. Flora, Vol. 97, No. 2, Tax Notes (October 14, 2002), p. 265.

Employment Lawyers Face Hidden Final IRS Rules on IRS Form 1099 for Attorney-Related Payments, by Robert W. Wood and Jonathan R. Flora, Vol. 19, No. 12, BNA Employment Discrimination Report (September 25, 2002), p. 347.

Further Thoughts on the Bad Biehl Decision, Vol. 96, No. 13, Tax Notes (September 23, 2002), p. 1777.

Deducting Legal Fees For Criminal Defense, Damage Awards Update 5:06, Tax Analysts Taxation of Damages Discussion Group (August 30, 2002).

Capitalizing Legal Fees Related To Acquisition, Damage Awards Update 5:06, Tax Analysts Taxation of Damages Discussion Group (August 30, 2002).

Military Retirement Pay In Divorce Taxable To Wife, Damage Awards Update 5:06, Tax Analysts Taxation of Damages Discussion Group (August 30, 2002).

Americans With Disabilities Act Recovery Taxable, Damage Awards Update 5:06, Tax Analysts Taxation of Damages Discussion Group (August 30, 2002).

Malpractice Claim Has Value For Estate Tax Purposes, Damage Awards Update 5:06, Tax Analysts Taxation of Damages Discussion Group (August 30, 2002).

Observations on Taxation of Infringement Recoveries, Vol. 96, No. 9, Tax Notes (August 26, 2002), p. 1273.

More Attorneys’ Fee Cases, Cal Tax Network (August 2002), p. 8.

Resolve Tax Treatment Before Settlement Agreement Is Signed, San Francisco Daily Journal (July 30, 2002), p. 5. Simultaneously published in San Francisco Daily Journal (July 30, 2002), p. 5.

Insurance Settlement Payments Includable in Gross Income, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Redemption of Divorced Wife’s Stock Taxable to Her, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Qualified Settlement Fund Not Subject To Information Reporting, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Disability Benefits Partially Excludable From Income, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Settlement Payments Not Exempt From FICA/FUTA Taxes, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Individual Can’t Deduct Ex-Wife’s Attorney’s Fees as Alimony, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Support Payments Don’t Terminate on Spouse’s Death, Aren’t Deductible as Alimony, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Payment to Pension Plan in Settlement of Lawsuit Is Not a Contribution, IRS Rules, Damage Awards Update 5:05, Tax Analysts Taxation of Damages Discussion Group (July 9, 2002).

Proposed Attorney Fee Reporting Regulations: Déjà Vu?, Vol. 96, No. 3, Tax Notes (July 15, 2002), p. 409.

IRS Again Proposes Tax Reporting on Attorneys’ Fees, Vol. 18, No. 24, BNA’s Employment Discrimination Report (June 12, 2002), p. 712.

Proposed Attorneys’ Fee Regs Issued (Again), Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

No Deduction for Business-Related Litigation Expenses, Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

Employment Taxes Applicable to Settlement, Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

Settlement Held Wages, Not Excludable, Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

Is a Sale or Exchange Required to Get Capital Gains?, Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

More Attorneys’ Fee Cases, Damage Awards Update 5:04, Tax Analysts Taxation of Damages Discussion Group (June 10, 2002).

Consider Tax Treatment of Environmental Payments, Vol. 20, No. 4, The Real Estate Tax Digest (April 2002), p. 3.

Tax Treatment of Will Contest Recoveries, Vol. 11, No. 3, California Tax Lawyer (Spring 2002), p. 17.

 

 

 

MERGERS AND ACQUISITIONS

 

Thinking the Unthinkable: Recognizing Gain on 351 Transfers, Vol. 11, No. 5, The M&A Tax Report (December 2002), p. 1.

Capital-Gains Treatment a Hard Sell for M&A Litigation Acquisition Litigation: Must There Be a Sale or Exchange for Capital Treatment?, Bowne Review for CFOs & Investment Bankers (December 2002); abstracted from Acquisition Litigation: Must There Be a Sale or Exchange for Capital Treatment?, Vol. 11, No. 2, The M&A Tax Report (September 2002), p. 1.

Deducting Legal Fees for Criminal Defense, Vol. 11, No. 4, The M&A Tax Report (November 2002), p. 1.

Business Purpose and Economic Substance: Catch Me If You Can, Vol. 11, No. 4, The M&A Tax Report (November 2002), p. 5; abstracted in M&A Business Purpose Cannot Be A Sham, Bowne Review for CFOs & Investment Bankers (January 2003).

Capital Idea! Legal Fees in Acquisitions, Vol. 11, No. 4, The M&A Tax Report (November 2002), p. 7.

Should Built-In Tax Liability Be Taken Into Account in Valuing a Company?, Vol. 11, No. 3, The M&A Tax Report (October 2002), p. 1.

ISOs and Section 83(b) Elections, by Robert W. Wood and Jonathan R. Flora, Vol. 11, No. 3, The M&A Tax Report (October 2002), p. 1.

Capitalizing M&A Legal Fees, Vol. 11, No. 3, The M&A Tax Report (October 2002), p. 7.

Acquisition Litigation: Must There Be a Sale or Exchange for Capital Treatment?, Vol. 11, No. 2, The M&A Tax Report (September 2002), p. 1.

Stock Option Ruminations, Vol. 11, No. 2, The M&A Tax Report (September 2002), p. 1.

Do It Through a Conduit: Active Businesses Under Section 355, Vol. 11, No. 2, The M&A Tax Report (September 2002), p. 6.

More Step Transaction Authority, Vol. 11, No. 1, The M&A Tax Report (August 2002), p. 1.

Business Purpose: A Universal Maxim?, Vol. 10, No. 12, The M&A Tax Report (July 2002), p. 1.

Another Spoiled Spinoff, Vol. 10, No. 12, The M&A Tax Report (July 2002), p. 1.

Merger of S and C Corporations Yields Suspended Loss Benefit, Vol. 10, No. 12, The M&A Tax Report (July 2002), p. 4.

Sale vs. Reorganization: Eye of the Beholder?, Vol. 10, No. 12, The M&A Tax Report (July 2002), p. 5.

How Not To Do A Section 355 Spinoff, Bowne Review for CFOs and Investment Bankers (June/July 2002), p. 6; abstracted from Spinoffs: The Good, the Bad, and the Ugly, Vol. 10, No. 10, The M&A Tax Report (May 2002), p. 1.

“E” is for Excellent: The New 355(e) Regulations, Vol. 10, No. 11, The M&A Tax Report (June 2002), p. 1.

Section 269 and Acquisitions, Vol. 10, No. 11, The M&A Tax Report (June 2002), p. 7.

Valuing Stock Options: Guidance in the Maze, Vol. 10, No. 10, The M&A Tax Report (May 2002), p. 1.

Spinoffs: The Good, the Bad, and the Ugly, Vol. 10, No. 10, The M&A Tax Report (May 2002), p. 1.

Revisiting the Step Transaction Doctrine, Vol. 11, No. 3, California Tax Lawyer (Spring 2002), p. 15.

Proposed Golden Parachute Regs, Vol. 10, No. 9, The M&A Tax Report (April 2002), p. 1.

Fizzled German Tax Law, Vol. 10, No. 9, The M&A Tax Report (April 2002), p. 1.

More Poison Pills, Vol. 10, No. 9, The M&A Tax Report (April 2002), p. 4.

Nondeductible Stock Redemption Payments, Vol. 10, No. 9, The M&A Tax Report (April 2002), p. 4.

Spins in the News Again, Vol. 10, No. 8, The M&A Tax Report (March 2002), p. 1.

The Step Transaction Doctrine: Beyond the Grasp of Mere Mortals?, Vol. 94, No. 7, Tax Notes (February 18, 2002), p. 923.

Media Rights for Sports Franchises: Separate Assets?, Vol. 10, No. 7, The M&A Tax Report (February 2002), p. 1.

Overhead Deduction on Acquisition Allowed, Vol. 10, No. 7, The M&A Tax Report (February 2002), p. 6.

Step Transaction Doctrine and Mergers, Vol. 10, No. 6, The M&A Tax Report (January 2002), p. 6.

 

MISCELLANEOUS

 

Deciding Whether, and How Much, Real Estate Has Been Given to Charity, Vol. 30, No. 1, Real Estate Taxation (4th Quarter 2002), p. 39.

Capitalizing Legal Fees in Real Estate Deals, Vol. 20, No. 9, Real Estate Tax Digest (November 2002), p. 3.

Good Flow Charts, Bad Tax System, Vol. 96, No. 11, Tax Notes (September 9, 2002), p. 1531.

Is a Sale or Exchange Required to Get Capital Gains?, Cal Tax Network (August 2002), p. 10.

Recent Interesting Tax Opinions, Cal Tax Network (April 2002), p. 1.

Developments in Home Offices, Vol. 29, No. 3, Real Estate Taxation (2nd Quarter 2002), p. 116.

Employment Taxes — Advantage Exotic Dancers, Vol. 11, No. 3, California Tax Lawyer (Spring 2002), p. 13.

Rabys’ Article on Expert Witnesses Was Very Much Appreciated, Vol. 95, Tax Notes (May 13, 2002), p. 1089.

A Surfeit of Sheppardisms?, Vol. 94, No. 10, Tax Notes (March 11, 2002), p. 1367.

Exotic Dancers Win Tax Disputes, Vol. 94, No. 4, Tax Notes (January 28, 2002), p. 498.

Dirty Taxing, Vol. 115, No. 7, Los Angeles Daily Journal (January 11, 2002), p. 7. Simultaneously published in San Francisco Daily Journal (January 11, 2002), p. 7.

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