Janicelynn Asamoto Park
Associate
Janicelynn Asamoto Park is an associate in the Tax Department.
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Last week, in McKelvey v. Commissioner¸[1] the U.S. Tax Court held that the extension of a typical variable prepaid forward contract (“VPFC”) did not give rise to a taxable exchange to the obligor because a VPFC is solely an obligation, and not property, within the meaning of section 1001 of the Internal Revenue Code. The … Continue Reading
On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain debt instruments as equity for all federal income tax purposes. The final and temporary regulations narrow considerably the scope of the proposed regulations … Continue Reading
The U.S. Internal Revenue Service (IRS) and the Department of the Treasury (“Treasury”) have published proposed regulations that would modify the device and active trade or business requirements for tax-free spin-offs under section 355 of the Code in three important respects. First, the proposed regulations clarify the “device” test and its relationship to the “business … Continue Reading
Tax Court Rules that Extensions of Variable Prepaid Forward Contracts Do Not Result in Taxable Exchanges
By David S. Miller, Richard M. Corn, Martin T. Hamilton and Janicelynn Asamoto Park on Posted in financial products, Notable Decisions
Final and Temporary Debt-Equity Regulations Issued by the IRS
By David S. Miller and Janicelynn Asamoto Park on Posted in IRS
Proposed Regulations Under Section 355 Clarify Device and Active Trade or Business Requirements for Spin-offs
By Richard M. Corn and Janicelynn Asamoto Park on Posted in IRS, Section 355
