2007
TOPICS:
All articles written by Robert W. Wood (unless otherwise noted)
Taxing Damages After Second Murphy Decision , NELA The Employee Advocate, (Summer/Fall 2007), p. 22.
IRS Cracking Down on Government Settlements
New Scrutiny on Tax Deduction of Settlements , Reprinted with permission from the New York State Bar Journal , November/December 2007, Vol. 79, No. 9, published by the New York State Bar Association, One Elk Street, Albany, NY 12207.
Taxes as an Element of Damages
Big Legal Fee Tax Trap
Can You Get Increased Taxes as Damages?
Audits Mandatory for Some Settlement Payments, Profile Raised for Others
Thoughts on 'Thinking Outside the Code'
Damages for Tax Consequences
Audit Crackdown on Deductibility of Government Settlements
Waiting to Exhale: Murphy Part Deux and Taxing Damage Awards
Litigation Settlements and Income in Respect of a Decedent
Taxing Matters in Settling Cases , Vol. 27, No. 6, California Lawyer (June 2007), p. 41.
Hidden Taxes in Options Backdating Probe
What's Really Important in Murphy
Tax Effects of the Stock Options Backdating Flap
Structured Settlements: Are Factoring and Commuting Different? , Vol. 38, No. 4, The Tax Adviser (April 2007), p. 204.
Tax Treatment of Legal Malpractice Recoveries
When High-Priced Celebrity Lawyers Are Tax Deductible , Reprinted with permission from the New York State Bar Journal , February 2007, Vol. 79, No. 2, published by the New York State Bar Association, One Elk Street, Albany, NY 12207.
More on Interest in Tax Malpractice Cases
Consider Who Gets Tax Deduction For Settlement Payments
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, 2nd. Edition , 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 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 , Vol. 15, No. 12, The M&A Tax Report (July 2007), p. 7.
Book Review: International Assest Acquisitions, by Committee on Negotiated Acquistions, 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 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 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-Versus-Employee Issues Arise in Multiple Contexts
Independent Contractor Vs. Employee: Domino Effect of Recharacterization
U.S. Tax Code Offers Expatriates Benefits, With Restrictions
Am I a Return Preparer?
Don't Forget Expatriate Tax Restrictions, Benefits Under U.S. Code
Loans, Taxes and the Subprime Lending Flap
Tax Stories Can Be Ribald - Who Knew?
Number Crunching and Qualified Small-Business Stock Gains
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
Tax Opinions and Nonopinions: How Far Does Liability Go?
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