2003

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Attorney Fees: Rebellious Circuit Don’t Need No Stinkin’ Lien Law, by Robert W. Wood and Dominic L. Daher, Vol. 101, No. 12, Tax Notes (December 22, 2003), p. 1427.

IRS’ MSSP on Lawsuit Awards, Settlements: Useful as a Gelding at a Stud Farm?, by Robert W. Wood and Dominic L. Daher, No. 245, Daily Tax Report (December 22, 2003), p. J-1.

Attorney Fees Fiasco: Can’t Anyone Help?, Vol. 101, No. 7, Tax Notes (November 17, 2003), p. 919.

Beating a Dead Horse: Tax Indemnity Payments to Ex-Spouses, by Robert W. Wood and Dominic L. Daher, Vol. 101, No. 7, Tax Notes (November 17, 2003), p. 875.

Tax Treatment of Attorney’s Fees in Litigation Recoveries — A Proposal Recommending New Legislation and Regulations, Vol. 12, No. 4, California Tax Lawyer (Fall 2003), p. 16.

Class Action Attorney Fees: Even Bigger Tax Problems?, by Robert W. Wood and Dominic L. Daher, Vol. 101, No. 4, Tax Notes (October 27, 2003), p. 507.

Attorneys’ Fees: Maverick Circuit Says, ‘Oregon Good, Calif. Bad’, by Robert W. Wood and Dominic L. Daher, Vol. 101, No. 1, Tax Notes (October 6, 2003), p. 91.

Slip Slidin’ Away: The Ninth Circuit Welcomes Cotnam Into the Fold?, by Robert W. Wood and Dominic L. Daher, Vol. 21, No. 13, BNA’s Employment Discrimination Report (October 1, 2003), p. 411.

Contingent Attorney’s Fees in Class Action Cases — From Bad to Worse for Taxpayer-Plaintiffs, by Robert W. Wood and Dominic L. Daher, Vol. 99, No. 4, Journal of Taxation (October 2003), p. 228.

Tax Effects of Antitrust Payments and Recoveries, Vol. 12, No. 3, California Tax Lawyer (Summer 2003), p. 18.

‘Civil Rights Tax Relief’ Fails: How Do You Spell Relief? Vol. 100, No. 3, Tax Notes (July 21, 2003), p. 401.

Thoughts on the Origin of the Clintons’ Legal Fees, Vol. 100, No. 2, Tax Notes (July 14, 2003), p. 265.

Proposed Nondeductibility for Punitive Damages: Will it Work?, Vol. 100, No. 1, Tax Notes (July 7, 2003), p. 99.

Tax Treatment of Business Litigation Recoveries — Capital Gain vs. Ordinary Income, Vol. 99, No. 1, Journal of Taxation (July 2003), p. 27.

Tax Treatment of Attorneys’ Fees: Whose Law Applies?, Vol. 99, No. 99, Tax Notes (July 7, 2003), p. 1651.

Tax Bill Prevents Employers From Deducting Punitive Damages, Vol. 20, No. 24, BNA Employment Discrimination Report (June 11, 2003), p. 789.

Deductibility of Attorneys’ Fees: Half a Loaf?, Vol. 20, No. 22, BNA Employment Discrimination Report (May 28, 2003), p. 727.

More Confusion on Tax Treatment of Attorneys’ Fees: Whose Law Applies?, Vol. 20, No. 21, BNA Employment Discrimination Report (May 21, 2003), p. 701.

Should the Securities Industry Settlement Be Deductible?, Vol. 99, No. 1, Tax Notes (April 7, 2003), p. 101.

Lawyers Fees: Beware Final IRS Rules on Forms 1099 for Attorneys, Vol. 12, No. 2, California Tax Lawyer (Spring 2003), p. 10.

Where

Can You Litigate Your Federal Tax Case?, by David B. Porter, Vol. 98, Tax Notes (January 7, 2003), p. 558.

Reporting Lawyers’ Fees, Vol. 23, No. 1, California Lawyer (January 2003), p. 17.

MERGERS AND ACQUISITIONS

Business Litigation Recoveries — The Capital vs. Ordinary Debate Continues to Smolder, Vol. 12, No. 5, The M&A Tax Report (December 2003), p. 2.

Confidentiality Bites: What You Don’t Know Can Hurt You…, by David B. Porter, Vol. 12, No. 4, The M&A Tax Report (November 2003), p. 3.

Are We Having Fun Yet? Employee Equity Choices for LLCs, by Dominic L. Daher and Robert W. Wood, Vol. 12, No. 4, The M&A Tax Report (November 2003), p. 1.

Reciprocity and Section 83: What’s Good for the Goose?, Vol. 12, No. 3, The M&A Tax Report (October 2003), p. 1.

Bye Bye Love, Bye Bye Happiness: Is Giving Up Flow-Through Taxation to Go Public Really Worth It?, by Dominic L. Daher and Robert W. Wood, Vol. 12, No. 3, The M&A Tax Report (October 2003), p. 5.

Control, and Immediately After: Whither 351?, Vol. 12, No. 2, The M&A Tax Report (September 2003), p. 3.

Executive Option? Not So Fast…, Vol. 12, No. 1, The M&A Tax Report (August 2003), p. 1.

Stock Options vs. Restricted Stock: The Following Microsoft?, Vol. 12, No. 1, The M&A Tax Report (August 2003), p. 5.

Buying (or Selling) Foreign Businesses, Vol. 11, No. 12, The M&A Tax Report (July 2003), p. 1.

Business Purpose Redux?, Vol. 11, No. 12, The M&A Tax Report (July 2003), p. 2.

Valuation Verisimilitude, by Dominic L. Daher and Robert W. Wood, Vol. 11, No. 12, The M&A Tax Report (July 2003), p. 5.

Is it Football Time Yet?, Vol. 11, No. 12, The M&A Tax Report (July 2003), p. 7.

New Bill Would Bar Settlement Deductions, Vol. 11, No. 11, The M&A Tax Report (June 2003), p. 1.

357(d) Proposed Regulations in the Works?, Vol. 11, No. 11, The M&A Tax Report (June 2003), p. 5.

Book Review: How Much is Enough?, Vol. 11, No. 11, The M&A Tax Report (June 2003), p. 8.

Economic Substance: Who and Why?, Vol. 11, No. 10, The M&A Tax Report (May 2003), p. 1.

Reasonable Compensation?, Vol. 11, No. 10, The M&A Tax Report (May 2003), p. 4.

Boot or Booty?, Vol. 11, No. 10, The M&A Tax Report (May 2003), p. 7.

Buyers Beware (of Transferee Tax Obligations), Bowne Review for CFOs & Investment Bankers (April 2003), p. 7; abstracted from Transferee Liability: What, Me Worry?, Vol. 11, No. 7, The M&A Tax Report (February 2003), p. 1.

Tracking Stock Tribulations, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 1.

Bankruptcy Notes, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 2.

Spins: Does Anyone Care Anymore?, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 3.

Tax Considerations in Acquisitions: No Such Thing as a Free Lunch?, by David B. Porter, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 5.

ABA Books Navigate Antitrust Merger Review, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 6.

Can You Use the Installment Method on Corporate Liquidations?, Vol. 11, No. 9, The M&A Tax Report (April 2003), p. 7.

Don’t Forget Bankruptcy NOL Rules, Vol. 11, No. 8, The M&A Tax Report (March 2003), p. 1.

Stock Buyback’s: Reporting Obligations?, Vol. 11, No. 8, The M&A Tax Report (March 2003), p. 4.

Anti-INDOPCO Regulations (Part Two), Vol. 11, No. 8, The M&A Tax Report (March 2003), p. 6.

To Expense or Capitalize: That is the Question, Vol. 11, No. 8, The M&A Tax Report (March 2003), p. 8.

Transferee Liability: What, Me Worry?, Vol. 11, No. 7, The M&A Tax Report (February 2003), p. 1.

INDOPCO: Dead Without a Wake?, Vol. 11, No. 7, The M&A Tax Report (February 2003), p. 4.

COD Income, Reporting, and Injustice (Or, How the IRS Makes You Pay Taxes On Income You Don’t Have), by Jonathan R. Flora, Vol. 11, No. 6, The M&A Tax Report (January 2003), p. 1.

When Redemptions Are Treated as Dividends: Whither Basis?, Vol. 11, No. 6, The M&A Tax Report (January 2003), p. 3.

Sham Transactions: Do You Know One When You See It?, Vol. 11, No. 6, The M&A Tax Report (January 2003), p. 7.

Legislative INDOPCO Reversal?, Vol. 11, No. 6, The M&A Tax Report (January 2003), p. 7.

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

MISCELLANEOUS

Home Office Rules and Charitable Contributions: Never the Twain Shall Meet?, Vol. 30, No. 4, Real Estate Taxation (3rd Quarter 2003), p. 186.

How to Kill the AMT, Vol. 100, No. 7, Tax Notes (August 18, 2003), p. 970.

Home Offices: Exceptions to the Harsh Regime, Vol. 21, No. 5, Real Estate Tax Digest (May 2003), p. 3.

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