Tax Planning for Troubled Corporations (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