Tax Notes, Vol. 124, No. 11, Sept. 14, 2009
In this article, Viva I: (1) explain the history of the AHYDO rules, (2) walk readers through the maze of their application, (3) explain attempts by Treasury and Congress to mitigate their barb during the financial crisis, and (4) offer some long-term solutions to the problem of what to do when the rules rear their heads once again in a few months.
Read the full text here or download the article TNT 2009-9-14 AHYDO this article was also reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013)