2006

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Structured Settlements: Factor vs. Commute?, Vol. 113, No. 13, Tax Notes (December 25, 2006), p. 1147.

The Federal Income Taxation of Contingent Attorneys’ Fees: Patchwork by Congress and Supreme Court Creates Uncertainty, The Monthly Digest of Tax Articles (December 25, 2006), p. 10.

Big Board Payback, Vol. 113, No. 9, Tax Notes (November 27, 2006), p. 836.

Murphy: It’s Not Just About Basis, Vol. 113, No. 8, Tax Notes (November 20, 2006), p. 789.

Opt-In, Opt-Out Hopscotch Over Taxes in Class Actions, Vol. 113, No. 7, Tax Notes (November 13, 2006), p. 654.

Structuring Attorney Fees When You’re Not a Solo, Vol. 42, No. 12, Trial (November 2006), p. 62.

Wood Looks at the Flip Side of Murphy v. IRS, Vol. 113, No. 2, Tax Notes (October 9, 2006), p. 188.

Tax Practitioner Wood Offers Top 10 Reasons Why His Favorite Case is D.C. Circuit’s Murphy, Vol. 27, No. 13, BNA Employment Discrimination Report (October 4, 2006), p. 413.

Top 10 Reasons Murphy is My Favorite Tax Case, No. 190, Daily Tax Report (October 2, 2006), p. J-1.

‘It’s Deductible’: Sharp Pencils and Boeing’s Imbroglio, Vol. 112, No. 12, Tax Notes (September 18, 2006), p. 1053.

Final Regs Fuel Fuss Over Attorney Fee Reporting, Vol. 112, No. 11, Tax Notes (September 11, 2006), p. 929.

Tax-Free Damages: Murphy’s Law Opens Floodgates, Vol. 112, No. 10, Tax Notes (September 4, 2006), p. 850.

What’s Deductible? Case Law Provides Guidance for Celebrities Looking to Deduct Legal Fees, California CPA (September 2006), p. 15.

New Regulations Address 1099s for Lawyers’ Fees, Vol. 8, No. 4, Journal of Tax Practice & Procedure (August/September 2006), p. 31.

Reporting Of Lawyers’ Fees: New Regulations on 1099s, Vol. 15, No. 3/4, California Tax Lawyer (Summer/Fall 2006), p. 37.

Structuring Attorney Fees When You’re Not a Solo, Vol. 78, No. 6, New York State Bar Association Journal (July/August 2006), p. 44.

Identity of Payer Problems With Settlements, Vol. 112, No. 3, Tax Notes (July 17, 2006), p. 255.

What’s Excludable? Despite Amendment, IRC Sec. 104 Leaves Some Questions Unanswered, California CPA (July 2006), p. 31.

Damage Awards: Sickness, Causation, and More, Vol. 111, No. 11, Tax Notes (June 12, 2006), p. 1233.

When You Are Not a Solo, Should You be Concerned About Structuring Fees?, Vol. 28, No. 3, California Civil Litigation Reporter (June 2006), p. 114.

Taxing Punitives, Law Finance Group (2006).

No Free Lunch: When Someone Pays Your Legal Fees, Tax Notes (May 22, 2006), p. 909.

Rulings Make Qualified Settlement Funds More Attractive, Tax Notes (May 8, 2006), p. 673.

The GWE, a (Not So New) Tax Exclusion Worth a Look, by Robert W. Wood and Richard C. Morris, Vol. 37, No. 5, The Tax Adviser (May 2006), p. 286.

Paying the Piper: Executives and Legal Fees, The Monthly Digest of Tax Articles (May 2006), p. 56.

Stars and Their Legal Fees: Another Red Carpet?, Vol. 15, No. 2, California Tax Lawyer (Spring 2006), p. 36.

Legal Fee Structures, Law Firms, And Lawyers: Children of Childs?, Vol. 111, No. 2, Tax Notes (April 10, 2006), p. 173.

Denying Deductions Based on Public Policy, Vol. 110, No. 12, Tax Notes (March 27, 2006), p. 1415.

Contingent Attorney Fees in the Post-Banks Era, Vol. 110, No. 5, Tax Notes (February 6, 2006), p. 663.

Structuring Attorneys’ Fees: What’s All the Fuss?, Washington State Bar News (February 2006), p. 23.

Recent Damage Awards Decisions, The Monthly Digest of Tax Articles (February 2006), p. 55.

Wood Responds to Daley on Attorney Fee Puzzles, Vol. 110, No. 3, Tax Notes (January 23, 2006), p. 413.

Tax Deductions for Damage Payments: What, Me Worry?, Vol. 110, No. 2, Tax Notes (January 16, 2006), p. 243.

The Federal Income Taxation of Contingent Attorneys’ Fees: Patchwork by Congress and Supreme Court Creates Uncertainty, Vol. 67, No. 1, Montana Law Review (Winter 2006), p. 1.

General Welfare Exclusion Can Mean Tax-Free Money, by Robert W. Wood and Richard C. Morris, Vol. 15, No. 1, California Tax Lawyer (Winter 2006), p. 31.

MERGERS AND ACQUISITIONS

Gather (and Harvest) Your Losses While You May, Vol. 15, No. 5, The M&A Tax Report (December 2006), p. 1.

Webcast Review: “Building Blocks of Hedge Fund Taxation,” Sponsored by the ABA Section of Taxation and Center for Continuing Legal Education, reviewed by Richard C. Morris, Vol. 15, No. 5, The M&A Tax Report (December 2006), p. 3.

Successful Debt Restructuring (Part II of II), by Richard C. Morris, Vol. 15, No. 5, The M&A Tax Report (December 2006), p. 4.

Book Review: ABA’s Model Joint Venture Agreement with Commentary, reviewed by David B. Porter, Vol. 15, No. 5, The M&A Tax Report (December 2006), p. 7.

B Reorganizations: A Time to Kill?, Vol. 15, No. 4, The M&A Tax Report (November 2006), p. 1.

IRS Allows Do-Over for Installment Method Election, by Patrick A. Hoehne, Vol. 15, No. 4, The M&A Tax Report (November 2006), p. 3.

Successful Debt Restructuring (Part I of II), by Richard C. Morris, Vol. 15, No. 4, The M&A Tax Report (November 2006), p. 4.

Book Review: Reverse Mergers — Taking a Company Public Without an IPO, Vol. 15, No. 4, The M&A Tax Report (November 2006), p. 7.

2005 Tax Act Offers Good News and Bad News for Spinoffs, Bowne Review for CFOs & Investment Bankers (October 2006), p. 1; abstracted from Latest Tax Act Impacts Spin-Offs, Vol. 14, No. 12, The M&A Tax Report (July 2006), p. 1.

Successful Debt Restructuring, by Richard C. Morris, Vol. 15, No. 3, The M&A Tax Report (October 2006), p. 5.

Code Sec. 338(h)(10) and the Step Transaction Doctrine, by Richard C. Morris, Vol. 15, No. 3, The M&A Tax Report (October 2006), p. 1.

Capital Idea!, by Richard C. Morris, Vol. 15, No. 2, The M&A Tax Report (September 2006), p. 6.

Gain Recognition Agreements in Asset Reorganizations, by Richard C. Morris, Vol. 15, No. 1, The M&A Tax Report (August 2006), p. 5.

Latest Tax Act Impacts Spin-offs, Vol. 14, No. 12, The M&A Tax Report (July 2006), p. 1.

Basis and S Corporation Shareholder Loans (Part I of II), by Richard C. Morris, Vol. 14, No. 12, The M&A Tax Report (July 2006), p. 5.

The New Reversionary Conversion Doctrine?, by Richard C. Morris, Vol. 14, No. 11, The M&A Tax Report (June 2006), p. 4.

Proposed Redemption Regulations Withdrawn, by Richard C. Morris, Vol. 14, No. 11, The M&A Tax Report (June 2006), p. 6.

Better Luck Next Time: Deductions Costs of Failed Business Transactions, by David B. Porter, Vol. 14, No. 10, The M&A Tax Report (May 2006), p. 6.

(Not So) Golden Parachutes, Vol. 14, No. 9, The M&A Tax Report (April 2006), p. 7.

Second Helpings on Sandwiches, with Richard C. Morris, Vol. 14, No. 9, The M&A Tax Report (April 2006), p. 6.

Book Review: Negotiated Acquisitions of Companies, Subsidiaries and Divisions, by Lou R. Kling and Eilenn T. Nugent, reviewed by Stuart M.Vogt, Vol. 14, No. 9, The M&A Tax Report (April 2006), p. 5.

All in the Family: NOLs and Other Family Jewels, Vol. 14, No. 8, The M& A Tax Report (March 2006), p.7.

“A” Reorganizations Revisited, by Richard C. Morris, Vol.14, No. 8, The M&A Tax Report (March 2006), p. 3.

Corporate Inversion Reporting, Vol. 14, No. 8, The M&A Tax Report (March 2006), p. 1.

Reporting Acquisitions of Control, Vol. 14, No. 7, The M&A Tax Report (February 2006), p. 7.

Book Review: Mergers, Acquisitions and Buyouts: A Transactional Analysis of the Governing Tax, Legal and Accounting Considerations, by Martin Ginsburg and Jack Levin, reviewed by Richard C. Morris, Vol. 14, No. 7, The M&A Tax Report (February 2006), p. 6.

Can

Your Joint Venture Deduct Research and Experimental Expenditures?, by David B. Porter, Vol. 14, No. 7, The M&A Tax Report (February 2006), p. 1.

The Continuing Conundrum of Escrowed Stock, Vol. 14, No. 6, The M&A Tax Report (January 2006), p. 5.

Those Were the Days: Times Mirror and How to Make a Sandwich (Part II of II), by Robert W. Wood and Richard C. Morris, Vol. 14, No. 6, The M&A Tax Report (January 2006), p. 1.

MISCELLANEOUS

FICA Wages and the Exemption for State Instrumentalities, by David B. Porter, Vol. 53, No. 3, The Exempt Organization Tax Review (September 2006), p. 279.

State Instrumentalities Can Escape FICA Obligations, by David B. Porter, Vol. 15, No. 3/4, California Tax Lawyer (Summer/Fall 2006), p. 19.

Omnipresent Seinfeld Episodes Contain Ample Clues About Tax Policy, No. 152, BNA Daily Tax Report (August 8, 2006), p. J-1.

The Advantages of Selling Appreciated Assets Via a Structured Sale, Vol. 37, No. 8, The Tax Adviser (August 2006), p. 472.

Selling Real Estate: Improving Installment Sales, Vol. 22, No. 6, Tax Management Real Estate Journal (June 7, 2006), p. 124.

Substitution of Installment Obligors, by Stuart Vogt and Robert W. Wood, Vol. 15, No. 1, California Tax Lawyer (Winter 2006), p. 19.

Articles