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MISUNDERSTOOD?
STATE LAW AND TAX TREATMENT OF PERSONAL GOODWILL, PART 1 State Law and Tax Treatment of Personal Goodwill, Part 1 By Robert W. Wood and Brian L. Beck The ownership of assets is fundamental to com-merce, yet precisely who owns what may be unclear PREPAID FORWARD CONTRACTS: WHAT’S ALL THE FUSS? THE M&A TAx REPORT 7 The buyer’s perspective is the mirror image of the seller’s. Upon making the $100 payment, Buyer B takes a $100 basis in the forward MERGER OF S AND C CORPORATIONS YIELDS SUSPENDED LOSS The following article is adapted and reprinted from the M&A Tax Report, Vol. 10, No. 12, July 2002, Panel Publishers, New York, NY. MERGER OF S AND C CORPORATIONS YIELDS SUSPENDED LOSS BENEFIT TAXING EARN-OUT PAYMENTS THE M&A Tax RePoRT 3 Taxing earn-out Payments By Robert W. Wood • Wood LLP • San Francisco How much is a transaction really worth? Suppose you read online that the total MA THE T R - WOOD LLP The SEPTEMBER 2016 V OLUME 25, N UMBER 2 The Monthly Review of Taxes, Trends & Techniques October 31 , MA& T R EDITOR-IN-CHIEF Robert W. Wood Wood LLP San Francisco PRODUCTION EDITOR Mina Chung Wood LLP San Francisco ADVISOR BOARD Donald P. Board NONRECOGNITION OF WARRANTS EXCHANGED IN A CORPORATE 6 THE M&A TAX REPORT but for the fact that the property received in the exchange consists not only of stock or securities, but also of “other property or money.” In that CODE SEC. 83(B) ELECTIONS: THE GOOD, THE BAD, AND THE UGLY THE M&A TAX REPORT 3 forfeit the property receiving no cash back. Here, you get to deduct $100, but only as a capital loss. WOOD LLP - SAN FRANCISCO, CAPUBLICATIONSPRACTICE AREASLEGAL ASSISTANTSCONTACT USMEDIASAN FRANCISCO, CASAN FRANCISCO CA SALES TAXSAN FRANCISCO TAX LAWYERSAN FRANCISCO TAX PROPERTYSAN FRANCISCO FIND A LAWYERSAN FRANCISCO LAWYERS NETWORKSAN FRANCISCO TAX RATE About Us; Contact Us; Attorneys; Legal Assistants; Practice Areas; Publications; Media; Recognition PAYMENTS TO CANCEL STOCK OPTIONS AND SARS ON TAKEOVER ARE Payments to Cancel Stock Options and SARs on Takeover are Deductible by Robert W. Wood' San Francisco Despite what may seem to be the prevailing norm that expenses incurred in connection with 12 WAYS TO DEDUCT LEGAL FEES UNDER NEW TAX LAWS TAX NOTES FEDERAL, OCTOBER 7, 2019 111 tax notes federal WOODCRAFT 12 Ways to Deduct Legal Fees Under New Tax Laws by Robert W. Wood You are a plaintiff in a lawsuit and just settled REDEMPTION EXPENSES NONDEDUCTIBLE: AVOIDING REDEMPTION The following article is adapted from reprinted from the M&A Tax Report, Vol. 7, No. 7, February 1999, Panel Publishers, New York, NY. PREPAID FORWARD CONTRACTS: WHAT’S ALL THE FUSS? THE M&A TAx REPORT 7 The buyer’s perspective is the mirror image of the seller’s. Upon making the $100 payment, Buyer B takes a $100 basis in the forward DEDUCTION ON STOCK BUYBACKS? (PART I) The following article is adapted and reprinted from the M&A Tax Report, Vol. 8, No. 9, April 2000, Panel Publishers, New York, NY. DEDUCTIONS ON STOCK BUYBACKS? DEDUCTING CORPORATE LEGAL SETTLEMENTS The The Monthly Review of Taes Trends Techniues + PLS renew your subscription Tax Report with the e version by June 2013, and we will cut the price by 10%! Call 800-2 48-3 24 8 to renew and save! TAX OPINIONS THE SEC WAY Tax Opinions the SEC Way By Robert W. Wood and Donald P. Board Tax practitioners are often accused of not seeing the big picture. By training or by inclination, we CALIFORNIA SOURCING AND M&A e FEBRUARY 2013 VOLUME 21, NUMBER 7 The Monthly Review of Taxes, Trends & Techniques PLUS renew your subscription Tax Report with the e version by November 2012, and we will cut the price by 10%! Call 800-248-3 248 to renew and save! Receive your newsletter CODE SEC. 83(B) ELECTIONS: THE GOOD, THE BAD, AND THE UGLY THE M&A TAX REPORT 3 forfeit the property receiving no cash back. Here, you get to deduct $100, but only as a capital loss. WOOD LLP - SAN FRANCISCO, CAPUBLICATIONSPRACTICE AREASLEGAL ASSISTANTSCONTACT USMEDIASAN FRANCISCO, CASAN FRANCISCO CA SALES TAXSAN FRANCISCO TAX LAWYERSAN FRANCISCO TAX PROPERTYSAN FRANCISCO FIND A LAWYERSAN FRANCISCO LAWYERS NETWORKSAN FRANCISCO TAX RATE About Us; Contact Us; Attorneys; Legal Assistants; Practice Areas; Publications; Media; Recognition PAYMENTS TO CANCEL STOCK OPTIONS AND SARS ON TAKEOVER ARE Payments to Cancel Stock Options and SARs on Takeover are Deductible by Robert W. Wood' San Francisco Despite what may seem to be the prevailing norm that expenses incurred in connection with 12 WAYS TO DEDUCT LEGAL FEES UNDER NEW TAX LAWS TAX NOTES FEDERAL, OCTOBER 7, 2019 111 tax notes federal WOODCRAFT 12 Ways to Deduct Legal Fees Under New Tax Laws by Robert W. Wood You are a plaintiff in a lawsuit and just settled REDEMPTION EXPENSES NONDEDUCTIBLE: AVOIDING REDEMPTION The following article is adapted from reprinted from the M&A Tax Report, Vol. 7, No. 7, February 1999, Panel Publishers, New York, NY. PREPAID FORWARD CONTRACTS: WHAT’S ALL THE FUSS? THE M&A TAx REPORT 7 The buyer’s perspective is the mirror image of the seller’s. Upon making the $100 payment, Buyer B takes a $100 basis in the forward DEDUCTION ON STOCK BUYBACKS? (PART I) The following article is adapted and reprinted from the M&A Tax Report, Vol. 8, No. 9, April 2000, Panel Publishers, New York, NY. DEDUCTIONS ON STOCK BUYBACKS? DEDUCTING CORPORATE LEGAL SETTLEMENTS The The Monthly Review of Taes Trends Techniues + PLS renew your subscription Tax Report with the e version by June 2013, and we will cut the price by 10%! Call 800-2 48-3 24 8 to renew and save! TAX OPINIONS THE SEC WAY Tax Opinions the SEC Way By Robert W. Wood and Donald P. Board Tax practitioners are often accused of not seeing the big picture. By training or by inclination, we CALIFORNIA SOURCING AND M&A e FEBRUARY 2013 VOLUME 21, NUMBER 7 The Monthly Review of Taxes, Trends & Techniques PLUS renew your subscription Tax Report with the e version by November 2012, and we will cut the price by 10%! Call 800-248-3 248 to renew and save! Receive your newsletter CODE SEC. 83(B) ELECTIONS: THE GOOD, THE BAD, AND THE UGLY THE M&A TAX REPORT 3 forfeit the property receiving no cash back. Here, you get to deduct $100, but only as a capital loss. LIABILITY FOR TAX OPINIONS: WHAT'S AN OPINION AND WHO CAN 61 January 2008 TAXES—THE TAX MAGAZINE ©R.W. Wood Robert W. Wood practices law with Wood & Porter, in San Francisco (www.woodporter.com), and is the author of TAXATION OF DAMAGE AWARDS AND SETTLEMENT PAYMENTS (3d Ed. Tax Institute 2005 with 2006 Update) available at www.damageawards.org. STOCK BUYBACKS: REPORTING OBLIGATIONS? The following article is adapted and reprinted from the M&A Tax Report, Vol. 11, No. 8, March 2003, Panel Publishers, New York, NY. STOCK BUYBACKS: REPORTING OBLIGATIONS? EXPLORING CONTINGENT FEE TAX ADVICE WOODCRAFT 1618 TAX NOTES, JUNE 12, 2017 filed within 120 days of the taxpayer’s receiving a written notice of the examination of, or a written challenge to, the original tax return.4 2. NEW TAX ON LITIGATION SETTLEMENTS, NO DEDUCTION FOR LEGAL TAX NOTES, MARCH 5, 2018 1387 tax notes® WOODCRAFT New Tax on Litigation Settlements, No Deduction for Legal Fees by Robert W. Wood Tax cuts are supposed to be good. Yet as IRS LAWYER AUDITS: REVIEW AND BEST PRACTICES FOR THE IRS LAWYER AUDITS: REVIEW AND BEST PRACTICES FOR THE BUSINESS LAWYER'S SMALL OR SOLO PRACTICE ROBERT W WOOD Although no one likes an IRS audit, lawyers may dislike dealing with the IRS even more than most people. Perhaps it is because an audit may mean that the IRS begins poking into the financial affairs HOW LEGAL SETTLEMENTS AND JUDGMENTS ARE TAXED 22 Business Law News • The State Bar of California sickness.2 Note the “physical” requirement. Before 1996, “personal” injury damages were tax-free. That meant emotional distress, defamation, and many other legal injuries WHAT HAPPENS IF YOU HAVE TO COLLECT ON YOUR TAX INDEMNITY The following article is reprinted from The M&A Tax Report, Vol. 12, No. 6, January 2004, Panel Publishers, New York, NY. WHAT HAPPENS IFYOU HAVE TO
TAXING EARN-OUT PAYMENTS THE M&A Tax RePoRT 3 Taxing earn-out Payments By Robert W. Wood • Wood LLP • San Francisco How much is a transaction really worth? Suppose you read online that the total WHEN THE IRS SAYS A LIQUIDATION IS NOT A LIQUIDATION When the IRS Says a Liquidation Is Not a Liquidation By Robert W. Wood and Dashiell C. Shapiro Groucho: Now it says, the party of the secondpart
GETTING ADDITIONAL DAMAGES FOR ADVERSE TAX CONSEQUENCES Getting Additional Damages for Adverse Tax Consequences By Robert W. Wood How and when we are paid, whether for services or property, can influence the amount of tax we have to pay.* About Us
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