2004

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Effective Date of Attorney Fee Deduction Misses Many Judgments, Vol. 105, No. 13, Tax Notes (December 20, 2004), p. 1643.

Washington Attorneys’ Lien Law, The Tax Adviser (December 2004), p. 729.

What Happens When Companies Pay Executives’ Legal Fees?, Vol. 23, No. 48, Tax Management Weekly Report (November 29, 2004), p. 1.

Jobs Act Attorney Fee Provision: Is it Enough?, Vol. 105, No. 8, Tax Notes (November 15, 2004), p. 961.

Attorney Fees: The Amici Believe the Taxpayer is Correct, Vol. 105, No. 6, Tax Notes (November 1, 2004), p. 760.

Taxation of Legal Fees When Paid by a Corporation for an Employee, Vol. 13, No. 4, California Tax Lawyer (Fall 2004), p. 29.

Attorney Fees and Partnership Theory: Another View, Vol. 105, No. 2, Tax Notes (October 11, 2004), p. 250.

Post-1996 Act Section 104 Cases: Where are We Eight Years Later? Vol. 105, No. 1, Tax Notes (October 4, 2004), p. 68.

New Uses for Structured Settlements: Non-Physical Injury Cases, Vol. 27, Wyoming Lawyer (October 2004), p. 18.

The Element of Willfulness: A Defense for Tax Shelters, by David B. Porter, Vol. 104, No. 12, Tax Notes (September 13, 2004), p. 1225.

Settlements and Judgments: Attorney Fees and Section 104 Cases, Vol. 104, No. 7, Tax Notes (August 16, 2004), p. 733.

Structured Settlements in Non-Physical Injury Cases: Tax Risks, Vol. 104, No. 5, Tax Notes (August 2, 2004), p. 511.

Recent Developments in Contingent Attorney Fee Area, Vol. 104, No. 3, Tax Notes (July 19, 2004), p. 314.

Were Sex Abuse Payments for Physical Injuries or Sickness?, Vol. 104, No. 1, Tax Notes (July 5, 2004), p. 56.

Class Actions and the Attorneys’ Fees Conundrum, by Robert W. Wood and Dominic L. Daher, The Tax Adviser (July 2004), p. 428.

Structured Settlements Plus Nonqualified Assignments, Expanding the Field of Structures, Vol. 6, No. 3, J. of Tax Practice and Procedure (June – July 2004), p. 29.

Hyperbolic Viewpoint on Attorney Fee Cases Proves Too Much, Vol. 103, No. 13, Tax Notes (June 28, 2004), p. 1675.

Settlements & Taxes: The Seven Deadly Sins, Vol. 27, No. 3, Wyoming Lawyer (June 2004), p. 32.

Tax Horrors of Sexual Molestation Recoveries, Vol. 13, No. 3, California Tax Lawyer (Summer 2004), p. 13.

Tax Treatment of Settlements and Judgments, Vol. 103, No. 9, Tax Notes (May 31, 2004), p. 1134; abstracted in Vol. 4, No. 21, Tax Law Abstracts: Practitioners Services (May 28, 2004), published by LSN Tax Law & Policy Journals.

Income From the Assignment of Non-Qualified Settlement Payments, California Tax Delegation to Washington, D.C. (Internal Revenue Service, Senate Finance Committee and United States Treasury Department), published in Tax Analysts (May 10, 2004).

Another Bite at the Apple — Ninth Circuit Takes Another Look at the Attorneys’ Fee Fiasco and Changes Its Tune, by Robert W. Wood and Dominic L. Daher, Vol. 6, No. 2, Tax Practice & Procedure (April – May 2004), p. 45.

Using Non-Physical Injury Structured Settlements — Any Tax Risks?, Vol. 13, No. 2, California Tax Lawyer (Spring 2004), p. 19.

Second Circuit Further Muddies the Water on the Attorneys’ Fee Mess, Vol. 13, No. 2, California Tax Lawyer (Spring 2004), p. 5.

When Clients Must Report Fee Payments, Vol. 24, No. 4, California Lawyer (April 2004), p. 41.

Everybody Loves Raymond — Second Cir. Weighs In on Atty Fees, Vol. 102, No. 13, Tax Notes (March 29, 2004), p. 1639.

Second Circuit Perpetuates the Attorneys — Fee Snafu, Vol. 22, No. 11, BNA Employment Discrimination Report (March 17, 2004), p. 309.

Shot Through the Heart: Tax Indemnity Payments to Your Former Better Half, No. 44, Daily Tax Report (March 8, 2004), p. J-1.

Taxation of Settlements and Judgments, Vol. 102, No. 9, Tax Notes (March 1, 2004), p. 1120.

IRS Audit Guide on Damage Awards Misses the Mark, by Robert W. Wood and Dominic L. Daher, Vol. 102, No. 8, Tax Notes (February 23, 2004), p. 1013.

Settlements and Taxes: The Seven Deadly Sins, Vol. 76, No. 2, New York State Bar Journal (February 2004), p. 52.

Are Tax Indemnity Payments to an Ex-Spouse Taxable?, by Robert W. Wood and Dominic L. Daher, The Tax Adviser (February 2004), p. 83.

Tax Reports on Lawyers’ Fees: Sneaky IRS Rules on Forms 1099, Vol. 28, No. 1, NTLA Advocate (January/February 2004), p. 10.

Attorneys’ Fee Debacle Keeps Going, Going, and Going As Mutinous Sixth Circuit Refuses Reliance on Lien Law Analysis, by Robert W. Wood and Dominic L. Daher, No. 11, Daily Tax Report (January 20, 2004), p. J-1.

 

 

MERGERS AND ACQUISITIONS

 

Deferred Compensation Provision of the Jobs Act, Vol. 13, No. 5, The M&A Tax Report (December 2004), p. 1.

Spin-off Regulations Proposed (Part I), Vol. 13, No. 5, The M&A Tax Report (December 2004), p. 8.

Tax Implications of Companies Paying Employees? Legal Fees, Vol. 13, No. 4, The M&A Tax Report (November 2004), p. 4.

Treatment of Options in M&A Deals: Let’s Kick It Old School, Vol. 13, No. 3, The M&A Tax Report (October 2004), p. 1.

Revisiting the Step Transaction Doctrine: The Legacy of American Bantam Car?, by Robert W. Wood and Dominic L. Daher, Vol. 13, No. 3, The M&A Tax Report (October 2004), p. 4.

Capitalizing Legal Fees Related to Acquisitions: Will INDOPCO Ever Die?, by Robert W. Wood and Dominic L. Daher, Vol. 13, No. 3, The M&A Tax Report (October 2004), p. 7.

Information Return Reporting for Settlement Payments: Are Most Corporations in the Dark?, by Robert W. Wood and Dominic L. Daher, Vol. 13, No. 3, The M&A Tax Report (October 2004), p. 8.

M&A Dealmakers: Do Not Overlook Tax Implications, Bowne Review for CFOs & Investment Bankers (October 2004).

Tax Aspects of M&A Deals: A Pervasive and Intricate Part of Any Transaction, Vol. 13, No. 1, The M&A Tax Report (August 2004), p. 5.

Payors of Punitive Damages: Have They Made a Deal With the Devil Himself?, Vol. 13, No. 1, The M&A Tax Report (August 2004), p. 8.

Tax Allocations Really Do Work, Vol. 12, No. 12, The M&A Tax Report (July 2004), p. 6.

INDOPCO Era of Uncertainty Comes to a Close, by Robert W. Wood and Dominic L. Daher, Vol. 12, No. 12, The M&A Tax Report (July 2004), p. 7.

Don’t Wait Until It’s Too Late: Address Tax Issues in M&A Deals Sooner Rather Than Later, Vol. 12, No. 10, The M&A Tax Report (May 2004), p. 3.

Corporate Lawsuit Settlements? What to Watch for and How Not to Get Burned , by Robert W. Wood and Dominic L. Daher, Vol. 12, No. 10, The M&A Tax Report (May 2004), p. 5.

Noncompetes: Do the Tax Issues Ever End?, by Robert W. Wood and Dominic L. Daher, Vol. 12, No. 6, The M&A Tax Report (January 2004), p. 1.

New Development in U.S. International Tax — Redemptions Taxable as Dividends, by David B. Porter, Vol. 12, No. 6, The M&A Tax Report (January 2004), p. 6.

What Happens If You Have to Collect on Your Tax Indemnity Agreement? Are You Taxed on the Tax?, by Robert W. Wood and Dominic L. Daher, Vol. 12, No. 6, The M&A Tax Report (January 2004), p. 7.

 

MISCELLANEOUS

 

Capitalizing Legal Fees in Real Estate Transactions, Vol. 32, No. 1, Real Estate Taxation (4th Quarter 2004), p. 41.

Home Improvement or Home Disaster? Can the Tax Law Help When You Get Taken?, Vol. 13, No. 4, California Tax Lawyer (Fall 2004), p. 27.

Deciding Whether, and How Much, Real Estate Has Been Given to Charity, Vol. 15, No. 6, Taxation of Exempts (May/June 2004), p. 284.

Home Office Rules and Charitable Contributions: Together Forever or Forever Apart?, Vol. 22, No. 5, Real Estate Tax Digest (May 2004), p. 13.

Articles