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Tax Planning for Troubled Corporations (2007) [Perfect Paperback]

Gordon D. Henderson and Stuart J. Goldring (Author)


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Book Description

0808015958 978-0808015956 November 16, 2007
Tax Planning for Troubled Corporations, by noted tax attorneys Gordon D. Henderson and Stuart J. Goldring, provides crystal clear analysis and guidance for tax, financial and legal advisors to troubled companies. This classic treatise publishes annually and each edition examines the full gamut of tax aspects, consequences and considerations of bankruptcy and non-bankruptcy restructuring of financially troubled businesses -- from the corporation's initial tax payment and reporting obligations through the claims resolution process, to the payment and discharge of tax claims pursuant to a confirmed Chapter 11 plan. HIGHLIGHTS OF THE 2007 EDITION: With updated discussions and expanded coverage, the 2007 Edition is thoroughly revised to account for all new developments that have occurred in this dynamic area of the law since publication of the 2006 Edition, including relevant legislation, important IRS rulings and regulations, and new case law. Highlights of new developments covered in the 2007 Edition include: - Court addresses timing of cancellation of debt in liquidating bankruptcy case. - IRS declares cancellation of debt income resulted from conversion of a convertible note. - IRS approves remedial provisions of a bankruptcy court order restricting stock transfers that could adversely affect a debtor s NOL carryforwards under Code §382. - IRS finalizes Code §382 regulations involving stock distributions from ESOPs - IRS addresses fluctuation-in-value issues under Code §382 on a case-by-case basis. - Fifth Circuit weighs in on family attribution under Code §382, and affirms the Tax Court s decision, in Garber Industries Holding Co. - IRS privately rules that three sister investment funds that passively invest together did not constitute a single entity for Code §382 purposes. - IRS privately rules that a loss corporation s diligence procedures satisfied its duty of inquiry with respect to the identification of its 5% shareholders. - IRS issues temporary re

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About the Author

Gordon D. Henderson has been a partner and is now of counsel, in the law firm of Weil, Gotshal & Manges LLP in New York City. He received his B.A. degree from Harvard College, and his J.D. degree from Harvard Law School. He has had extensive experience in major bankruptcy cases extending over 25 years. He has Chaired the Tax Section of the New York State Bar Association, the Committee on Corporation Law of the Association of the Bar of the City of New York, and the Policy Advisory Group for the New York Joint Legislative Commission to Study the New York State Tax Laws. Stuart J. Goldring is a partner in the law firm of Weil, Gotshal & Manges LLP in New York City. He received a Bachelors in Business Administration degree from the University of Michigan, and his J.D. from the University of Michigan Law School. He also received an LL.M. in Taxation from New York University School of Law. He has extensive experience in advising debtors, creditors, and potential acquirers and investors in troubled companies, spanning over 20 years. He serves on the Executive Committee of the Tax Section of the New York State Bar Association and is Co-Chairman of the Committee on Bankruptcy and Losses.

Product Details

  • Perfect Paperback: 902 pages
  • Publisher: CCH, Inc. (November 16, 2007)
  • Language: English
  • ISBN-10: 0808015958
  • ISBN-13: 978-0808015956
  • Product Dimensions: 9.9 x 6.8 x 2.5 inches
  • Shipping Weight: 4 pounds
  • Amazon Best Sellers Rank: #5,099,445 in Books (See Top 100 in Books)

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Inside This Book (learn more)
Key Phrases - Statistically Improbable Phrases (SIPs): (learn more)
postdischarge injunction, worthless stock deduction, administrative expense treatment, quickie refund, disputed ownership fund, prepetition taxes, option attribution rules, postconfirmation taxes, postpetition taxes, substantial nonbusiness assets, qualified settlement fund, eighth priority claim, consolidated return group, nondebt financial instruments, postconfirmation setoff, redetermination rule, tax allocation agreement, tax court proceeding, accrual basis debtor, old loss corporation, oversecured tax claims, postpetition portions, contested liability exception, qualified business indebtedness, reattribution election
Key Phrases - Capitalized Phrases (CAPs): (learn more)
United States, Supreme Court, Footnote Continued, Eleventh Amendment, Chief Counsel Advice, Tax Notes, Seventh Circuit, Ninth Circuit, Fifth Circuit, Internal Revenue Code, Bankruptcy Act, Sixth Circuit, Fourth Circuit, Eleventh Circuit, Tax Section, Third Circuit, Tenth Circuit, Second Circuit, Prudential Lines, New York State Bar Association, Eighth Circuit, Daily Tax Report, Collecting Process, Litigation Guideline Memorandum, Ist Cir
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