2007

TOPICS:

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

 

 

TAXATION OF DAMAGE AWARDS

 

Taxing Damages After Second Murphy Decision, NELA The Employee Advocate (Summer/Fall 2007), p. 22.

IRS Cracking Down on Government Settlements, The Tax Adviser (December 2007), p. 726.

New Scrutiny on Tax Deduction of Settlements, Vol. 79, No. 9, New York State Bar Association Journal (November/December 2007).

Taxes as an Element of Damages, Vol. 29, No. 5, California Civil Litigation Reporter (October 2007), p. 36.

Big Legal Fee Tax Trap, Vol. 27, No. 10, Tax Hotline (October, 2007), p. 12.

Can You Get Increased Taxes as Damages?, Vol. 33, No. 1, The Montana Lawyer (September, 2007), p. 8.

Audits Mandatory for Some Settlement Payments, Profile Raised for Others, Vol. 9, No. 4, Journal of Tax Practice and Procedure (August – September 2007), p. 35.

Thoughts on ‘Thinking Outside the Code’, Vol. 116, No. 9, Tax Notes (August 27, 2007), p. 803.

Damages for Tax Consequences, Vol. 116, No. 6, Tax Notes (August 6, 2007), p. 475.

Audit Crackdown on Deductibility of Government Settlements, Vol. 116, No. 5, Tax Notes (July 30, 2007), p. 371. Reprinted in Substance & Forum (March 18, 2008).

Waiting to Exhale: Murphy Part Deux and Taxing Damage Awards, Vol. 116, No. 4, Tax Notes (July 23, 2007), p. 265.

Litigation Settlements and Income in Respect of a Decedent, Vol. 116, No. 1, Tax Notes (July 2, 2007), p. 51.

Taxing Matters in Settling Cases, Vol. 27, No. 6, California Lawyer (June 2007), p. 41.

Hidden Taxes in Options Backdating Probe, Vol. 16, No. 2, California Tax Lawyer (Spring 2007), p. 22.

What’s Really Important in Murphy, Vol. 115, No. 4, Tax Notes (April 23, 2007), p. 397.

Tax Effects of the Stock Options Backdating Flap, Vol. 115, No. 2, Tax Notes (April 9, 2007), p. 137.

Structured Settlements: Are Factoring and Commuting Different?, Vol. 38, No. 4, The Tax Adviser (April 2007), p. 204.

Tax Treatment of Legal Malpractice Recoveries, Vol. 114, No. 6, Tax Notes (February 12, 2007), p. 665.

When High-Priced Celebrity Lawyers Are Tax Deductible, Vol. 79, No. 2, New York State Bar Association Journal (February 2007).

More on Interest in Tax Malpractice Cases, Vol. 114, No. 2, Tax Notes (January 15, 2007), p. 247.

Consider Who Gets Tax Deduction For Settlement Payments, Vol. 16, No. 1, California Tax Lawyer (Winter 2007), p. 9.

MERGERS AND ACQUISITIONS

Is M&A Merely Private Equity Now?, Vol. 16, No. 5, The M&A Tax Report (December 2007), p. 7.

Like-kind and Goodwill, Vol. 16, No. 5, The M&A Tax Report (December 2007), p. 6.

New Final Regulations on Reorgs, Vol. 16, No. 5, The M&A Tax Report (December 2007), p. 4.

Not Your Father’s Step Transaction Doctrine, Vol. 16, No. 5, The M&A Tax Report (December 2007), p. 1.

Stock Option Fundamentals, Vol. 16, No. 4, The M&A Tax Report (November 2007), p. 5.

Tax Accrual Workpapers May Be Privileged, Vol. 16, No. 4, The M&A Tax Report (November 2007), p. 3.

You Can’t Deduct Stock Redemption Payments, Vol. 16, No. 4, The M&A Tax Report (November 2007), p. 1.

More on Active Businesses and Code Sec. 355, Vol. 16, No. 3, The M&A Tax Report (October 2007), p. 4.

Built-in Gain Rules and Partnership Mergers, Vol. 16, No. 3, The M&A Tax Report (October 2007), p. 1.

Prepaid Income Not Built-in Gain Under Code Sec. 382 Rules, Vol. 16, No. 2, The M&A Tax Report (September 2007), p. 7.

Book Review: An Estate Planner’s Guide to Buy-Sell Agreements for the Closely Held Business, by Louis A. Mezzullo, reviewed by Alfred K. Leong, Vol. 16, No. 2, The M&A Tax Report (September 2007), p. 6.

What Transferor is Not a Transferor? A Shareholder, by Charles May, Vol. 16, No. 2, The M&A Tax Report (September 2007), p. 5.

IRS Expands Killer B Regulations, by Patrick A. Hoehne, Vol. 16, No. 2, The M&A Tax Report (September 2007), p. 4.

Continuity and Remoteness, Vol. 16, No. 2, The M&A Tax Report (September 2007), p. 1.

Practicing Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2007, reviewed by Alfred K. Leong, Vol. 16, No. 1, The M&A Tax Report (August 2007), p. 5.

Code Sec. 355 and Partnerships, Vol. 16, No. 1, The M&A Tax Report (August 2007), p. 6.

What’s an Active Business?, Vol. 15, No. 12, The M&A Tax Report (July 2007), p. 4.

Book Review: Private Equity Funds: Business Structure and Operations, by James M. Schell, reviewed by Larry Bercovich, Vol. 15, No. 12, The M&A Tax Report (July 2007), p. 7.

Book Review: International Asset Acquisitions, by Committee on Negotiated Acquisitions, ABA Section of Business Law, Vol. 15, No. 11, The M&A Tax Report (June 2007), p. 7.

Qualified Small Business Stock Number Crunching, Vol. 15, No. 11, The M&A Tax Report (June 2007), p. 1.

Noncompete vs. Stock Payments: Evergreen Issue, Vol. 15, No. 9, The M&A Tax Report (April 2007), p. 1.

Hot Stock is Taxable, by Patrick A. Hoehne, Vol. 15, No. 9, The M&A Tax Report (April 2007), p. 3.

Book Review: The Circular 230 Deskbook, by Blatmachr, Gans and Rios, reviewed by Larry Bercovich, Vol. 15, No. 9, The M&A Tax Report (April 2007), p. 4.

Stock Sales and Share Lending, by Richard C. Morris, Vol. 15, No. 9, The M&A Tax Report (April 2007), p. 5.

Second Bite at the Apple: Unwinding Subsidiary Liquidations Under Annual Accounting, by Stan D. Blyth, Vol. 15, No. 8, The M&A Tax Report (March 2007), p. 1.

Check-the-Box Milestone, by Richard C. Morris, Vol. 15, No. 8, The M&A Tax Report (March 2007), p. 4.

When Stock Issuances Are Meaningless, by Patrick A. Hoehne, Vol. 15, No. 7, The M&A Tax Report (February 2007), p. 1.

Worthless Partnership Interests, by Richard C. Morris, Vol. 15, No. 7, The M&A Tax Report (February 2007), p. 3.

Taking Comfort in Two, by Richard C. Morris, Vol. 15, No. 7, The M&A Tax Report (February 2007), p. 6.

IRS Regulations Now Give Certainty on Multistep M&A Transactions, by Richard C. Morris, Bowne Review for Dealmakers (January 2007), p. 9; abstracted from Code Sec. 338(h)(10) and the Step Transaction Doctrine, Vol. 15, No. 3, The M&A Tax Report (October 2006), p. 1.

Is it or Isn’t it a Dividend?, by Richard C. Morris, Vol. 15, No. 6, The M&A Tax Report (January 2007). p. 1.

Changes to the Zero-Basis Problem, by Richard C. Morris, Vol. 15, No. 6, The M&A Tax Report (January 2007). p. 6.

Book Review: Corporate Taxation Through the Lens of Mergers & Acquisitions, Including Cross Border Transactions, by Samuel Thompson, reviewed by Patrick A. Hoehne, Vol. 15, No. 6, The M&A Tax Report (January 2007). p. 7.

INDEPENDENT CONTRACTOR STATUS

Independent Contractor-Versus-Employee Issues Arise in Multiple Contexts, Vol. 2007, No. 192, BNA Daily Tax Report (October 4, 2007), p. J-1.

Independent Contractor vs. Employee: Domino Effect of Recharacterization, Vol. 16, No. 4, California Tax Lawyer (Fall 2007), p. 4.

MISCELLANEOUS

U.S. Tax Code Offers Expatriates Benefits, With Restrictions, Vol. 2007, No. 213, BNA Daily Tax Report (November 5, 2007), p. J-1. Also published in BNA Daily Report for Executives, Vol. 2007, No. 213 (November 5, 2007), p. J-1.

Am I a Return Preparer?, Vol. 117, No. 5, Tax Notes (October 29, 2007), p. 461.

Don’t Forget Expatriate Tax Restrictions, Benefits Under U.S. Code, BNA International Labor & Employment Law Report (October 12, 2007), p. 36.

Loans, Taxes and the Subprime Lending Flap, CalCPA Buzz (October 2, 2007).

Tax Stories Can Be Ribald — Who Knew?, Vol. 116, No. 10, Tax Notes (September 3, 2007), p. 899.

Number Crunching and Qualified Small-Business Stock Gains, Vol. 115, No. 4, Tax Notes (April 23, 2007), p. 343.

Structured Installment Sales as a Backup to § 1031 Exchange, Vol. 48, No. 6, BNA Tax Management Memorandum (March 19, 2007), p. 91.

Defer Tax and Be Safer With a Structured Sale, Vol. 27, No. 3, Tax Hotline (March 2007), p. 9.

Wood on the Private Annuity Regs and Structured Attorney Fees, Vol. 114, No. 5, Tax Notes (February 5, 2007), p. 577.

Tax Opinions and Nonopinions: How Far Does Liability Go?, Vol. 114, No. 4, Tax Notes (January 29, 2007), p. 427. Also published in Substance & Forum (February 27, 2008).

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