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| Preface | |
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| Tax Research | |
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| Overview of Tax Research | |
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| Steps in the Tax Research Process | |
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| Importance of the Facts to the Tax Consequences | |
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| The Sources of Tax Law | |
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| Tax Services | |
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| Citators | |
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| Computers as a Research Tool | |
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| Statements on Responsibilities in Tax Practice | |
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| Sample Work Papers and Client Letter | |
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| Problem Materials | |
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| Corporate Formations and Capital Structure | |
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| Organization Forms Available | |
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| Tax Definition of Common Business Entity Forms | |
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| Legal Requirements for Forming a Corporation | |
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| Tax Considerations in Forming a Corporation | |
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| Deferring Gain Or Loss Upon Incorporation | |
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| Choice of Capital Structure | |
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| Worthlessness of Stock or Debt Obligations | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| The Corporate Income Tax | |
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| Corporate Elections | |
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| General Formula For Determining the Corporate Tax Liability | |
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| Computing a Corporation's Taxable Income | |
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| Computing a Corporation's Income Tax Liability | |
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| Controlled Groups of Corporations | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Corporate Nonliquidating Distributions | |
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| Nonliquidating Distributions in General | |
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| Earnings and Profits (EandP) | |
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| Nonliquidating Property Distributions | |
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| Stock Dividends and Stock Rights | |
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| Stock Redemptions | |
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| Preferred Stock Bailouts | |
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| Stock Redemptions By Related Corporations | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Other Corporate Tax Levies | |
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| The Corporate Alternative Minimum Tax | |
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| Personal Holding Company Tax | |
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| Accumulated Earnings Tax | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Corporate Liquidating Distributions | |
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| Overview of Corporate Liquidations | |
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| General Liquidation Rules | |
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| Liquidation of a Controlled Subsidiary Corporation | |
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| Special Shareholder Reporting Issues | |
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| Special Corporate Reporting Issues | |
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| Recognition of Gain or Loss When Property Is Distributed In Retirement of Debt | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Corporate Acquisitions and Reorganizations | |
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| Taxable Acquisition Transactions | |
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| Comparison of Taxable and Tax-Free Acquisitions | |
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| Types of Reorganizations | |
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| Tax Consequences of Reorganizations | |
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| Acquisitive Reorganizations | |
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| Divisive Reorganizations | |
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| Other Reorganization Transactions | |
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| Judicial Restrictions on the Use of Corporate Reorganizations | |
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| Tax Attributes | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Consolidated Tax Returns | |
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| Source of the Consolidated Tax Return Rules | |
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| Definition of an Affiliated Group | |
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| Should a Consolidated Return Be Filed? | |
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| Consolidated Taxable Income | |
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| Computation of the Affiliated Group's Tax Liability | |
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| Intercompany Transactions | |
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| Dividends Received by Group Members | |
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| Consolidated Charitable Contributions Deduction | |
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| Net Operating Losses (Nols) | |
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| Consolidated Capital Gains and Losses | |
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| Stock Basis Adjustments | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Partnership Formation and Operation | |
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| Definition of a Partnership | |
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| Overview of Taxation of Partnership Income | |
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| Tax Implications of Formation of a Partnership | |
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| Partnership Elections | |
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| Partnership Reporting of Income | |
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| Partner Reporting of Income | |
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| Basis for Partnership Interest | |
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| Special Loss Limitations | |
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| Transactions Between a Partner and the Partnership | |
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| Family Partnerships | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Special Partnership Issues | |
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| Nonliquidating Distributions | |
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| Nonliquidating Distributions with Sec. 751 | |
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| Terminating an Interest in a Partnership | |
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| Special Forms of Partnerships | |
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| Tax Planning Considerations | |
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| Problem Materials | |
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| S Corporations | |
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| Should an S Election Be Made? | |
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| S Corporation Requirements | |
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| Election of S Corporation Status | |
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| S Corporation Operations | |
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| Taxation of the Shareholder | |
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| Basis Adjustments | |
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| S Corporation Distributions | |
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| Other Rules | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| The Gift Tax | |
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| Concept of Transfer Taxes | |
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| The Unified Transfer Tax System | |
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| Gift Tax Formula | |
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| Transfers Subject to the Gift Tax | |
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| Exclusions | |
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| Gift Tax Deductions | |
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| The Gift-Splitting Election | |
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| Computation of the Gift Tax Liability | |
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| Comprehensive Illustration | |
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| Basis Considerations for a Lifetime Giving Plan | |
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| Below-Market Loans: Gift And Income Tax Consequences | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| The Estate Tax | |
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| Estate Tax Formula | |
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| The Gross Estate: Valuation | |
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| The Gross Estate: Inclusions | |
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| Deductions | |
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| Computation of Tax Liability | |
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| Comprehensive Illustration | |
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| Liquidity Concerns | |
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| Generation-Skipping Transfer Tax | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Income Taxation of Trusts and Estates | |
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| Basic Concepts | |
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| Principles of Fiduciary Accounting | |
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| Formula for Taxable Income and Tax Liability | |
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| Distributable Net Income | |
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| Determining a Simple Trust's Taxable Income | |
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| Comprehensive Illustration: Determining a Simple Trust's Taxable Income | |
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| Determining Taxable Income for Complex Trusts and Estates | |
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| Comprehensive Illustration: Determining a Complex Trust's Taxable Income | |
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| Income in Respect of a Decedent | |
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| Grantor Trust Provisions | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Administrative Procedures | |
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| Role of the Internal Revenue Service | |
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| Audits of Tax Returns | |
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| Requests for Rulings | |
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| Due Dates and Penalties | |
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| Estimated Taxes | |
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| Other More Severe Penalties | |
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| Statute of Limitations | |
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| Liability for Tax | |
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| Tax Practice Issues | |
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| Problem Materials | |
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| U.S. Taxation of Foreign-Related Transactions | |
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| Jurisdiction to Tax | |
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| Taxation of U.S. Citizens and Resident Aliens | |
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| Taxation of Nonresident Aliens | |
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| Taxation of U.S. People Doing Business Abroad | |
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| Tax Planning Considerations | |
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| Compliance and Procedural Considerations | |
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| Problem Materials | |
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| Appendices | |
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| Tax Research Working Paper File | |
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| Completed Tax Forms | |
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| MARCS and ACRS Tables | |
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| Glossary | |
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| Statements on Responsibilities in Tax Practice (SRTPs) | |
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| Comparison of Tax Attributes for C Corporations, Partnerships, and S Corporations | |
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| Credit for State Death Taxes | |
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| Acturial Tables | |
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| Index of Code Sections | |
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| Index of Treasury Regulations | |
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| Index of Government Promulgations | |
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| Index of Court Cases | |
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| Subject Index | |