All articles written by Robert W. Wood (unless otherwise noted)
TAXATION OF DAMAGE AWARDS
Que Sera, Sera: Deducting Legal Fees , Vol. 125, No. 10, Tax Notes (December 07, 2009), p. 1115.
To Withhold or Not to Withhold on Settlements? , Vol. 125, No. 8, Tax Notes (November 23, 2009), p. 925.
Sausage, Capital Gain, and Settlement Payments , Vol. 125, No. 4, Tax Notes (October 26, 2009), p. 413.
Wood Responds to Critique of His Article , Vol. 125, No. 1, Tax Notes (October 5, 2009), p. 155.
Bruises, Settlements, and the Proposed 104 Regs , Vol. 124, No. 13, Tax Notes (September 28, 2009), p. 1337.
IRS Speaks Out on Employment Lawsuit Settlements , Vol. 124, No. 11, Tax Notes (September 14, 2009), p. 1091.
Tackling Post-Settlement Tax Issues , Vol. 40, No. 9, The Marin Lawyer (September 2009), p. 5.
Tax on Employment Settlements Addressed by IRS , Vol. 11, No. 4, Journal of Tax Practice & Procedure (August/September 2009), p. 51.
Top Ten Tenets for Trial Lawyers , Vol. 35, No. 4, Litigation, The Journal of the Section of Litigation, American Bar Association (Summer 2009), p. 38.
Ten Tax Rules To Keep In Mind , The Employee Advocate (Spring/Summer 2009), p. 37.
Third Circuit Upholds Tax Gross-Up To Damages Award , The Employee Advocate (Spring/Summer 2009), p. 28.
The QSF , The Employee Advocate (Spring/Summer 2009), p. 25.
Legal Fee Structures Can Hedge the Insecurities Many Lawyers Face , Los Angeles Daily Journal (August 28, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (August 28, 2009), p. 6.
Deducting Stock Offering Lawsuit Settlements , Vol. 124, No. 7, Tax Notes (August 17, 2009), p. 671.
Qualified Settlement Funds: A Mechanism Whose Time Has Come , Los Angeles Daily Journal (July 23, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (July 23, 2009), p. 6.
Should False Imprisonment Damages Be Taxable? , New York State Bar Association Journal (July/August 2009), p. 38.
Why Punitive Damages Should Remain Deductible , Vol. 124, No. 2, Tax Notes (July 13, 2009), p. 149.
One More Thing About the General Welfare Exception , Vol. 124, No. 1, Tax Notes (July 6, 2009), p. 83.
Damages Awards for Wrongful Imprisonment Should Be Tax-Free , Los Angeles Daily Journal (June 30, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (June 30, 2009), p. 6.
Updating General Welfare
Exception Authorities , Vol. 123, No. 12, Tax Notes (June 22, 2009), p. 1443.
Please Shelve Anti-Childs Proposals , Vol. 123, No. 11, Tax Notes (June 15, 2009), p. 1363.
Why False Imprisonment Recoveries Should Not Be Taxable , Vol. 123, No. 10, Tax Notes (June 8, 2009), p. 1217. Reprinted with permission in Vol. 20, No. 9, Prison Legal News (September 2009), p. 16.
Be Ready for Post-Settlement Tax Issues , Vol. 45, No. 6, Trial (June 2009), p. 32.
What to Tell Plaintiff Lawyers About Deducting Client Costs , The Successful California Accountant (Spring 2009), p. 6.
It's All About the Proof , Vol. 123, No. 8, Tax Notes (May 25, 2009), p. 1007.
Getting Additional Damages for Adverse Tax Consequences , Vol. 123, No. 4, Tax Notes (April 27, 2009), p. 423.
Attorney Fees: To Deduct or Not to Deduct , Vol. 123, No. 1, Tax Notes (April 6, 2009), p. 65.
Ten Tax Rules Litigators Should Know , California Bar Journal (April 2009), p. 14.
IRS Rules Insurance Bad-Faith Recovery Is Tax Free , Vol. 122, No. 10, Tax Notes (March 9, 2009), p. 1229.
When Litigation Settlements Face Fine or Capital Treatments , Vol. 122, No. 6, Tax Notes (February 9, 2009), p. 736.
Are All Settlement Payments Deductible? , Vol. 36, No. 2, Texas Tax Lawyer (February 2009), p. 34.
Ten Tax Rules Litigators Should Know , Vol. 9, No. 21, Daily Tax Report (February 4, 2009), p. 1.
Attorney Fees in Class Actions When Plaintiffs Are Taxed Too , Vol. 18, No. 3, Business Law Today (January/February 2009), p. 1.
Can Clients Save Taxes by "Partnership" With Lawyers? , Vol. 18, No. 1, California Tax Lawyer (Winter 2009), p. 13.
Cleaning Up: Tax Deductions for Restitution, Fines, and Penalties , Vol. 122, No. 4, Tax Notes (January 26, 2009), p.489.
A Taxing Process , Los Angeles Daily Journal (January 13, 2009), p. 5. Simultaneously published in San Francisco Daily Journal (January 13, 2009), p. 5.
Ten Things Attorneys Should Know About Deducting Client Costs , Vol. 9, No. 5, Daily Tax Report (January 9, 2009), p. 1.
Single-Claimant Qualified (468B)
Settlement Funds? , Vol. 122, No. 1, Tax Notes (January 5, 2009), p. 71.
MERGERS AND ACQUISITIONS
Independent Contractor or Employee: Guidelines to Ensure Compliance , by Richard Tay, Vol. 18, No. 5, The M&A Tax Report (December 2009), p. 7.
Deal Interrupted: Payments to Modify Stock Purchase Payments , Vol. 18, No. 5, The M&A Tax Report (December 2009), p. 5.
M&A: What You Need to Know Now 2009 , by David Libman, Richard Tay and Christopher Karachale, Vol. 18, No. 5, The M&A Tax Report (December 2009), p. 3.
Transformers: Beware Built-in Gains , Vol. 18, No. 5, The M&A Tax Report (December 2009), p. 1.
General Utilities Redux? , Vol. 18, No. 4, The M&A Tax Report (November 2009), p. 8.
Sales and Code Sec. 1234A , Vol. 18, No. 4, The M&A Tax Report (November 2009), p. 5.
Plowing Through Schering-Plough , Vol. 18, No. 4, The M&A Tax Report (November 2009), p. 1.
Personal and Transferee Liabilities , Vol. 18, No. 3, The M&A Tax Report (October 2009), p. 7.
Yet Another Risk About ESOP Transactions? , Vol. 18, No. 3, The M&A Tax Report (October 2009), p. 6.
Nixed ESOP Redemption Payments , Vol. 18, No. 3, The M&A Tax Report (October 2009), p. 5.
Repurchase Nuances and Code Sec. 83 , Vol. 18, No. 3, The M&A Tax Report (October 2009), p. 4.
Textron, Work Product and Corporate Deals , Vol. 18, No. 3, The M&A Tax Report (October 2009), p. 1.
When Deductible Fees Become Capital Contributions , Vol. 18, No. 2, The M&A Tax Report (September 2009), p. 6.
Tax Credits and the Cohan Rule , Vol. 18, No. 1, The M&A Tax Report (August 2009), p. 7.
Golden Parachute Guidance , Vol. 18, No. 1, The M&A Tax Report (August 2009), p. 5.
Back-to-Back Loans, S Corporations and Basis , Vol. 18, No. 1, The M&A Tax Report (August 2009), p. 4.
Deductible Termination Fees? , Vol. 18, No. 1, The M&A Tax Report (August 2009), p. 1.
Step Doctrine Ruling Can Cause Consternation for Dealmakers , Bowne Review for Dealmakers (August 2009), p. 3.
Easier 355 Rulings , Vol. 17, No. 12, The M&A Tax Report (July 2009), p. 5.
More Economic Substance Woes: Part II , Vol. 17, No. 12, The M&A Tax Report (July 2009), p. 4.
Sham Wow: Economic Substance and a New Sunrise , Vol. 17, No. 12, The M&A Tax Report (July 2009), p. 1.
Stock Offering Lawsuit Settlement Held Deductible , Vol. 17, No. 11, The M&A Tax Report (June 2009), p. 6.
Book Review: Structuring Venture Capital, Private Equity, and Entrepreneurial Transactions by Jack Levin , Vol. 17, No. 11, The M&A Tax Report (June 2009), p. 4.
ALI-ABA Course of Study: Corporate Taxation , by Richard I. Tay, Vol. 17, No. 11, The M&A Tax Report (June 2009), p. 3.
More Economic Substance Woes: Part I , Vol. 17, No. 11, The M&A Tax Report (June 2009), p. 1.
Using Attenuated NOL Carrybacks , Vol. 17, No. 10, The M&A Tax Report (May 2009), p. 7.
Book Review: Mergers, Acquisitions, and Buyouts by Martin D. Ginsburg and Jack S. Levin , Vol. 17, No. 10, The M&A Tax Report (May 2009), p. 5.
More on ESOP Redemption Deductions , Vol. 17, No. 10, The M&A Tax Report (May 2009), p. 5.
Deducting Pay Give-Backs , Vol. 17, No. 10, The M&A Tax Report (May 2009), p. 2.
Intangible Swaps Okay'ed , Vol. 17, No. 10, The M&A Tax Report (May 2009), p. 1.
Funny Money: Deducting "Reasonable" Compensation , Vol. 17, No. 9, The M&A Tax Report (April 2009), p. 5.
382 Bailout Guidance , Vol. 17, No. 9, The M&A Tax Report (April 2009), p. 4.
On the Cutting Edge of Capitalization , Vol. 17, No. 9, The M&A Tax Report (April 2009), p. 3.
The Acquisition Two-Step , Vol. 17, No. 9, The M&A Tax Report (April 2009), p. 1.
More "Midco" Transaction Advice: Part II , Vol. 17, No. 8, The M&A Tax Report (March 2009), p. 6.
Eighth Circuit Has General Mills for Breakfast , Vol. 17, No. 8, The M&A Tax Report (March 2009), p. 1.
More "Midco" Transaction Advice: Part I , Vol. 17, No. 7, The M&A Tax Report (February 2009), p. 7.
Shouldn't All Legal Fees Be Deductible? , Vol. 17, No. 7, The M&A Tax Report (February 2009), p. 4.
Continuity of Interest and Creditors , by Robert W. Wood and David E. Libman, Vol. 17, No. 7, The M&A Tax Report (February 2009), p. 1.
The Other Side of the “Reasonable Compensation” Coin , Vol. 17, No. 6, The M&A Tax Report (January 2009), p. 6.
Reconsidering Rescission , by David E. Libman, Vol. 17, No. 6, The M&A Tax Report (January 2009), p. 4.
Presto Chango, or Successor Liability , Vol. 17, No. 6, The M&A Tax Report (January 2009), p. 1.
INDEPENDENT CONTRACTOR STATUS
Pole Dancers: Employees or Contractors? , Vol. 125, No. 6, Tax Notes (November 9, 2009), p. 673.
IRS Pointers on Worker Classification , Vol. 37, No. 1, Texas Tax Lawyer (Fall 2009), p. 8.
Ten Things GAO Has to Say About Employee Contractor Misclassification , Vol. 9, No. 195, Daily Tax Report (October 13, 2009), p. J-1.
Bada-bing: Exotic Dancers, Wages and the IRS , Los Angeles Daily Journal (September 29, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 29, 2009), p. 6.
IRS Gives 10 Tips on Employees Versus Independent Contractors , Vol. 9, No. 172, Daily Tax Report (September 9, 2009), p. J-1.
Ten Things IRS Wants Workers to Consider When Contractors Become Employees , Vol. 9, No. 156, Daily Tax Report (August 17, 2009), p. J-1.
Ten More Consequences of Reclassifying Independent Contractors as Employees , Vol. 9, No. 140, Daily Tax Report (July 24, 2009), p. J-1.
Review: Crafting Independent Contractor Agreements , by Chris Welsch, Vol. 17, No. 12, The M&A Tax Report (July 2009), p. 6.
Ten Consequences of Reclassifying Independent Contractors as Employees , Vol. 9, No. 123, Daily Tax Report (June 30, 2009), p. J-1.
Legal Requirements That Influence Control
of Independent Contractors and Employees , Vol. 81, No. 2, New York State Bar Association Journal (February 2009), p. 36.
New Age Scrutiny on Employee vs. Contractor Liabilities , Vol. 2, State Bar of California Business Law News (2009), p. 11.
Employee Versus Independent Contractor Determinations Can Be Difficult in Cases Involving 'Of Counsel' Lawyers , Vol. 24, No. 1, BNA Corporate Counsel Weekly (January 7, 2009), p. 8.
How Workplace Laws Influence Contractor vs. Employee Controversies , National Employment Lawyers Association (Fall 2008/Winter 2009), p. 131.
MISCELLANEOUS
When An Innocent Spouse Seeks Tax Relief , Forbes.com (December 11, 2009). Also published in Investopedia.com (December 14, 2009).
The ABCs of Hobby Losses and Profit Motive , Vol. 25, No. 12, BNA Tax Management Real Estate Journal (December 2, 2009), p. 315.
Don't Try This at Home: The ABCs of Home Office Or Vacation Home Rental Deductions , Vol. 25, No. 12, BNA Tax Management Real Estate Journal (December 2, 2009), p. 310.
Navigating California's Tax System , Los Angeles Daily Journal (December 2, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (December 2, 2009), p. 6.
What If a Taxpayer Doesn't Have Receipts? , Forbes.com (November 24, 2009).
Regifiting: Obama, the Nobel Prize and the IRS , Forbes.com (November 19, 2009).
Do You Barter? The IRS Wants Its Cut , Forbes.com (November 11, 2009).
Ten Ways to Audit Proof Your Tax Return , Forbes.com (November 3, 2009).
Tax Breaks For Alcoholics, But Not Weight Watchers , Forbes.com (October 27, 2009).
Three Big Tax Mistakes You Make Every Day , Forbes.com (October 23, 2009).
When You've Got Taxable Income But No Cash , Forbes.com (October 12, 2009).
Even The IRS Has Time Limits , Forbes.com (October 8, 2009).
Ten Things to Keep in Mind as Offshore Amnesty Deadline Nears , Vol. 9, No. 188, Daily Tax Report (October 1, 2009), p. J-1.
Tax Amnesty Deadline Extended , Los Angeles Daily Journal (September 24, 2009), p. 5. Simultaneously published in San Francisco Daily Journal (September 24, 2009), p. 5.
Why Hire a Tax Expert? , Los Angeles Daily Journal (September 18, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 18, 2009), p. 6.
Ruling is a Frightening Step Back for Taxpayers’ Privacy Rights , Los Angeles Daily Journal (September 2, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 2, 2009), p. 6.
Why Litigators Need Tax Experts , Vol. 124, No. 9, Tax Notes (August 31, 2009), p. 885.
Foreign Assets — Your Clients' Reporting Requirements , by David B. Porter, San Francisco Attorney (Summer 2009), p. 40.
When the Service Claims Compensation is Unreasonable , Vol. 28, No. 4, NewsQuarterly, ABA Section of Taxation (Summer 2009), p. 12.
Ways to Steer Clear of IRS Tax Disputes , New York State Bar Association Journal (June 2009), p. 33.
Do You Have a Client Who Owns a Foreign Account, a Foreign Trust, or Foreign Stock? If You Do, Your Client Has Some Reporting to Do , by David B. Porter, The Successful California Accountant (Spring 2009), p. 14.
Tax Limericks , Vol. 123, No. 9, Tax Notes (June 1, 2009), p. 1151.
Ten Things You Need to Know About Return Preparer Penalties , Vol. 9, No. 99, Daily Tax Report (May 22, 2009), p. 1. Reprinted with permission in Tax Management Weekly Tax Report (June 1, 2009).
Ten Things You Need to Know About ‘Reasonable’ Compensation , Vol. 9, No. 68, Daily Tax Report (April 13, 2009), p. 1.
Giving Back Bonuses: Easy; Getting Tax Deductions: Priceless , Vol. 123, No. 2, Tax Notes (April 13, 2009), p. 185.
Alternative Approaches to Subtrust Funding in a Declining Economy , by David E. Libman, Journal of Practical Estate Planning (December 2008 - January 2009), p. 41.
TAX COLUMNS IN FORBES
When An Innocent Spouse Seeks Tax Relief , Forbes.com (December 11, 2009).
What If A Taxpayer Doesn't Have Receipts? , Forbes.com (November 24, 2009).
Regifiting: Obama, The Nobel Prize And The IRS , Forbes.com (November 19, 2009).
Do You Barter? The IRS Wants Its Cut , Forbes.com (November 11, 2009).
Ten Ways to Audit Proof Your Tax Return , Forbes.com (November 3, 2009).
Tax Breaks For Alcoholics, But Not Weight Watchers , Forbes.com (October 27, 2009).
Three Big Tax Mistakes You Make Every Day , Forbes.com (October 23, 2009).
When You've Got Taxable Income But No Cash , Forbes.com (October 12, 2009).
Even The IRS Has Time Limits , Forbes.com (October 8, 2009).
TAX COLUMNS IN DAILY JOURNAL
Legal Fee Structures Can Hedge the Insecurities Many Lawyers Face , Los Angeles Daily Journal (August 28, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (August 28, 2009), p. 6.
Qualified Settlement Funds: A Mechanism Whose Time Has Come , Los Angeles Daily Journal (July 23, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (July 23, 2009), p. 6.
Damages Awards for Wrongful Imprisonment Should Be Tax-Free , Los Angeles Daily Journal (June 30, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (June 30, 2009), p. 6.
A Taxing Process , Los Angeles Daily Journal (January 13, 2009), p. 5. Simultaneously published in San Francisco Daily Journal (January 13, 2009), p. 5.
Bada-bing: Exotic Dancers, Wages and the IRS , Los Angeles Daily Journal (September 29, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 29, 2009), p. 6.
Navigating California's Tax System , Los Angeles Daily Journal (December 2, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (December 2, 2009), p. 6.
Tax Amnesty Deadline Extended , Los Angeles Daily Journal (September 24, 2009), p. 5. Simultaneously published in San Francisco Daily Journal (September 24, 2009), p. 5.
Why Hire a Tax Expert? , Los Angeles Daily Journal (September 18, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 18, 2009), p. 6.
Ruling is a Frightening Step Back for Taxpayers’ Privacy Rights , Los Angeles Daily Journal (September 2, 2009), p. 6. Simultaneously published in San Francisco Daily Journal (September 2, 2009), p. 6.
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