2005

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Follow-Up to Article on Settling Suits With Charitable Payments, Vol. 109, No. 10, Tax Notes (December 5, 2005), p. 1370.

Discovering (or Revisiting) the General Welfare Exception from Gross Income, by Robert W. Wood and Richard C. Morris, Taxes — The Tax Magazine (December 2005), p. 39.

Taxation of Contingent Attorneys’ Fees Altered by the Jobs Act and the Supreme Court, Chapter 4, Vol. 1, 57th Annual Tax Institute, USC Law School 2005 Tax Institute.

Discharging Debt, Settling Litigation, and Singing the Blues, Vol. 109, No. 8, Tax Notes (November 21, 2005), p. 1041.

Assigning Pending Litigation: Tax Savings or Tax Disaster, Vol. 109, No. 7, Tax Notes (November 14, 2005), p. 910.

Litigation Settlements, Sales and Exchanges, and Section 1234A, Vol. 109, No. 6, Tax Notes (November 7, 2005), p. 776.

Better to Give Than Receive? Tax Effects of Returning Compensation, by Robert W. Wood and Richard C. Morris, Vol. 83, No. 11, Taxes — The Tax Magazine (November 2005), p. 25.

Resolving Litigation by Payments to Charity, Vol. 109, No. 5, Tax Notes (October 31, 2005), p. 633.

IRC Section 1234A Could Impact Taxation of Litigation Settlements, No. 209, BNA Daily Tax Report (October 31, 2005), p. J-1.

The General Welfare Exception to Gross Income, by Robert W. Wood and Richard C. Morris, Vol. 109, No.2, Tax Notes (October 10, 2005), p. 203.

Should Taxes Be Included in Damage Calculations?, Vol. 36, No. 10, The Tax Adviser (October 2005), p. 614.

Stakes Loom Large in Determining Taxation of Investment Loss Lawsuit Recoveries, No. 171, BNA Daily Tax Report (September 6, 2005), p. J-1.

Recent Damage Awards Decisions, Vol. 108, No. 11, Tax Notes (September 5, 2005), p. 1129.

Paying the Piper: Executives and Legal Fees, Vol. 108, No. 9, Tax Notes (August 22, 2005), p. 901.

Securities Lawsuit Recoveries: Capital Gain or Ordinary Income?, Vol. 108, No. 8, Tax Notes (August 15, 2005), p. 767.

More on Attorney Fees Post-Banks, Vol. 108, No. 7, Tax Notes (August 8, 2005), p. 707.

Tax Issues With Environmental Expenditures, Vol. 46, No. 16, Tax Management Memorandum (August 8, 2005), p. 323.

Structuring Attorney Fees: Kingdom of Heaven?, Vol. 108, No. 6, Tax Notes (August 1, 2005), p. 539.

Will the IRS Pursue Attorney Fees Post-Banks?, Vol. 108, No. 4, Tax Notes (July 18, 2005), p. 319.

Insurance Industry Settlements Revive Old Questions: When is a Payment a Nondeductible Penalty?, Vol. 103, No. 1, Journal of Taxation (July 2005), p. 47.

Ulcers and the Physical Injury/Physical Sickness Exclusion, Vol. 107, No. 12, Tax Notes (June 20, 2005), p. 1529.

An Ulcer Does Not Provide for Exclusion From Income, Los Angeles Daily Journal (June 3, 2005), p. 7. Simultaneously published in San Francisco Daily Journal (June 3, 2005), p. 7.

Contingent Fees in Anti-Discrimination Cases, Vol. 28, No. 3, Wyoming Lawyer (June 2005), p. 10.

Deducting Legal Fees for Governmental Corporate Investigations, The Tax Adviser (June 2005), p. 341.

Book Review: Bar Member Writes His 3rd Edition of Lawsuit-Taxing Primer, reviewed by Jonathan R. Flora, The Montana Lawyer Magazine (May 2005).

Boomerang Bonuses: Tax Effects When You Get It But Give It Back, by Robert W. Wood and Richard C. Morris, Vol. 107, No. 5, Tax Notes (May 2, 2005), p. 591.

Lawsuit Plaintiffs Can Lose Big Even When They Win Big, Vol. 25, No. 5, Tax Hotline (May 2005), p. 1.

Attorneys’ Fees Continue to Raise Tax Issues, Vol. 14, No. 2, California Tax Lawyer (Spring 2005), p. 17.

Tax Treatment of Class Action Attorneys’ Fees: After Banks, Journal of Tax Practice & Procedure (April – May 2005), p. 25.

The Case for Excluding Discrimination, Harassment Recoveries Under Section 104, No. 78, Daily Tax Reporter (April 25, 2005), p. J-1.

Contingent Fees and Tax Burdens: Planning After Commissioner v. Banks, Vol. 27, No. 2, Civil Litigation Reporter (April 2005), p. 52.

Tax Consequences of Personal Injury Damages — What Employers Need to Know, Vol. 6, No. 7, Corporate Business Taxation Monthly (April 2005), p. 13.

Optimizing Tax Treatment on Interest: More Practical Advice, Vol. 106, No. 12, Tax Notes (March 21, 2005), p. 1466.

Structured Settlements & Factoring: Never the Twain Shall Meet?, Vol. 106, No. 11, Tax Notes (March 14, 2005), p. 1278.

On Second Thought, More Disagreement With Jensen, Vol. 106, No. 10, Tax Notes (March 7, 2005), p. 1219.

Tax Aspects of Settling Corporate Lawsuits, Vol. 6, No. 6, Corporate Business Taxation Monthly (March 2005), p. 26.

Defendants Should Worry About Nondeductible Settlements, Vol. 106, No. 9, Tax Notes (February 28, 2005), p. 1064.

Supreme Court Attorney Fees Decision Leaves Much Unresolved, Vol. 106, No. 7, Tax Notes (February 14, 2005), p. 792.

Physical Sickness and the Section 104 Exclusion, Vol. 106, No. 1, Tax Notes (January 3, 2005), p. 121.

Structured Settlements and Nonqualified Assignments, The Tax Adviser (January 2005), p. 26.

Jobs Act Gives Partial Fix to Double Tax on Attorneys’ Fees, No. 37, The Witness Chair (Winter 2005), p. 1.

 

MERGERS AND ACQUISITIONS

 

Those Were the Days: Times Mirror and How to Make a Sandwich (Part I of II), by Robert W. Wood and Richard C. Morris, Vol. 14, No. 5, The M&A Tax Report (December 2005), p. 1.

IPO and Other Stock Issuance Costs Still Not Deductible, Bowne Review for CFOs & Investment Bankers (December 2005), p. 1.

Downstream Mergers, Consolidated Returns and the Step Transaction Doctrine, by Richard C. Morris, Vol. 14, No. 4, The M&A Tax Report (November 2005), p. 6.

Norman Conquest? Insolvency Reorganizations and Net Value, by Robert W. Wood and Stuart M. Vogt, Vol. 14, No. 3, The M&A Tax Report (October 2005), p. 4.

To Deduct or Not to Deduct: The Cost of an IPO, Vol. 14, No. 3, The M&A Tax Report (October 2005), p. 7.

Spin-off Rulings Revisited, Vol. 14, No. 2, The M&A Tax Report (September 2005), p. 1.

Paying the Golden Parachute Excise Tax, Vol. 14, No. 2, The M&A Tax Report (September 2005), p. 4.

Not Boring: Gary Lawrence’s Due Diligence in Business Transactions, Vol. 14, No. 2, The M&A Tax Report (September 2005), p. 7.

Transaction Costs in Acquisitions, Vol. 14, No. 1, The M&A Tax Report (August 2005), p. 4.

Golden Parachutes Again in the News, Vol. 14, No. 1, The M&A Tax Report (August 2005), p. 6.

U.K. Private Equity Tax Problems, Vol. 13, No. 11, The M&A Tax Report (June 2005), p. 6.

Book Review: Susan A. Berson’s Federal Tax Litigation, reviewed by David B. Porter, Vol. 13, No. 11, The M&A Tax Report (June 2005), p. 8.

Giving Back the Bonus, by Robert W. Wood and Richard C. Morris, Vol. 13, No. 10, The M&A Tax Report (May 2005), p. 5.

Inversion Transactions Revisited, Vol. 13, No. 8, The M&A Tax Report (March 2005), p. 5.

Spin Cycle, Vol. 13, No. 8, The M&A Tax Report (March 2005), p. 7.

How to Treat Stock Issuance Costs, Vol. 13, No. 7, The M&A Tax Report (February 2005), p. 4.

Spin-off Regulations Proposed: Part II, Vol. 13, No. 7, The M&A Tax Report (February 2005), p. 5.

New M&A Reporting Requirement, Vol. 13, No. 7, The M&A Tax Report (February 2005), p. 7.

Poison Pill Redux, Vol. 13, No. 7, The M&A Tax Report (February 2005), p. 8.

Ruminations on Intangibles, Vol. 13, No. 6, The M&A Tax Report (January 2005), p. 6.

 

MISCELLANEOUS

 

The Business Lawyer’s Ten Commandments to Live By in a Criminal Tax Investigation, by David B. Porter, Issue 4, Business Law News (2005), p. 1.

Mortgage Interest, Refinancing’s and the AMT, Vol. 21, No. 12, Tax Management Real Estate Journal (December 7, 2005), p. 360.

Private Annuity Trust Article Should Be Required Reading, Vol. 109, No. 4, Tax Notes (October 24, 2005), p. 546.

The IRS Narrows the Scope of Deductions for Environmental Remediation, Vol. 33, No. 1, Real Estate Taxation (4th Quarter 2005), p. 26.

Sarbanes Oxley Tax Bonus Raises Tax Problems, Vol. 14, No. 3, California Tax Lawyer (Summer 2005).

Breathing Life Into Installment Sales, Vol. 108, No. 3, Tax Notes (July 11, 2005), p. 201.

Substitution of Installment Obligors, by Stuart Vogt and Robert W. Wood, Vol. 107, No. 13, Tax Notes (June 27, 2005), p. 1621.

Don’t Let Drivers Take You to the Cleaners, Vol. 72, No. 2, Journal of Transportation Law, Logistics and Policy (Second Quarter 2005), p. 248.

Conservation Easements: Quid Pro Quo Revisited, Vol. 23, No. 2, Real Estate Tax Digest (February 2005), p. 17.

Home Offices: Exceptions to the Harsh Regime, Vol. 21, No. 1, Tax Management Real Estate Journal (January 5, 2005), p. 3.

Articles