Break for Companies with Holdings in Fannie Mae and Freddie Mac
By Eric S. Jones (Manatt, Phelps & Phillips, LLP)
A recent revenue procedure has broadened the scope of the Emergency Economic Stability Act of 2008 to permit banks and similar businesses to convert capital losses in stock of Fannie Mae and Freddie Mac to ordinary losses. Page 2
Return of the GAAR?
By Jasper L. (Jack) Cummings, Jr. (Alston & Bird LLP)
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Likely Tax Changes Under Obama Administration
By Michael Kerekes and Lawrence H. Cohen, JD, LL.M. (BDO Seidman, LLP)
The Obama plan calls for reductions in the corporate tax rate and implementation of tax changes that would encourage creation and retention of jobs, and provide a 50 percent business health care tax credit for some companies. The plan will increase tax rates on the top two personal tax brackets and will phase out itemized deductions for high income taxpayers, and lower taxes on middle and lower income taxpayers. Page 4
Financing, Tax Subsidies and Tax Credits for Solar Energy Projects: An Investor’s Perspective
By Eli M. Katz (Chadbourne & Parke)
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Beware of Harsh Penalties for Failure to Disclose Listed Transactions
By Charles M. Ruchelman and Leila D. Carney (Caplin & Drysdale)
The IRS is levying steep fines on companies that fail to disclose reportable transactions, even when the companies can point to good reasons for the mistake. A discussion of the procedures and possible ways to contest the fine. Page 11
Safe Harbor for Capital Contributions to Companies, Despite Section 382
By Charles Rubin (Gutter Chaves Josepher Rubin Forman Fleisher P.A.)
Under Code Section 382, capital contributions to a loss corporation will be disregarded if made within two years of a change in ownership. The IRS has provided four safe harbors that can protect capital contributions by some contributors. Page 13
New Internal Revenue Manual Section on Auditing U.S. Withholding Agents
By Edward Tanenbaum and Eva Farkas-DiNardo (Alston & Bird LLP)
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