The Internal Revenue Service has issued its long-awaited regulations on modification of debt instruments, but troubling questions remain
Article Abstract:
The main issue addressed in the final regulations of the IRS on the tax consequences of the modification of debt instruments is the situation under which a modification of the terms of a debt instrument results in the cancellation of the old debt instrument and the issuance of a new one in exchange. The final regulations require a two-step analysis but do not address financial instruments other than debt instruments. In general, the regulations provide that a change in any legal right or obligation of the issuer or holder of the instrument consitutes a modification. The regulations address many problems but some still remain.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1996
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New decisions from the 7th Circuit and the Court of Claims allow companies to deduct takeover costs as ordinary, not capital, expenses
Article Abstract:
Two cases decided by the US Court of Appeals for the 7th Circuit and the US Court of Federal Claims during 1997 hold that certain expenses incurred in defending a company from hostile takeover bids or in acquiring a capital asset are tax deductible. In A.E. Staley Manufacturing Co v. Commissioner the appeals court decided that such expenses, including investment bankers' fees and legal fees are normally deductible as either losses or business expenses. In Dana Corp v. US, the claims court decided that a particular legal retainer fee was deductible as a regular business expense.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1997
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Newly issued Internal Revenue Service regulations will limit the deduction of money spent to influence legislation and make lobbying more expensive
Article Abstract:
Internal Revenue Service regulations issued July 21 in compliance with the Omnibus Budget Reconciliation Act of 1993 eliminated the deductibility of expenditures connected with lobbying of federal and state lawmakers. The regulations affect taxpayers, trade associations, and other tax-exempt groups except some covered by Sec 501(c)(3). Only expenditures related to a communication with a 'covered executive branch official' and concerning a legislative proposal are affected.
Publication Name: The National Law Journal
Subject: Law
ISSN: 0162-7325
Year: 1995
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- Abstracts: The regulation of life insurance and superannuation investments in Australia. Conflicting signals for the trustees' duty to invest
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