Essentials of United States Taxation Book

• General Principles.
Overview of Taxation in the United States.
Federal Income Taxation: Structural Issues.
Federal Income Tax: Conceptual Issues.
Legislative, Administrative and Judicial Aspects.
• Corporate Taxation.
The Corporate Double Tax.
Forming a Corporation.
The Corporation as a Taxable Entity.
Cash and Property Distributions.
Redemptions.
Stock Dividends.
Tainted Stock.
Liquidations.
Taxable Acquisitions.
Reorganizations.
Combining Tax Attributes.
Penalty Provisions.
S Corporations.
• Partnership Taxation.
The Structure of Partnership Taxation.
Determining Distributive Shares.
A Partner's Outside Basis.
Nonliquidating Distributions.
A Partner's Transactions with the Partnership.
Acquisitions of Partnership Interests. Dispositions of Partnership Interests.
Loss Limitations.
Optional Basis Adjustments.
Partnership-Level Issues.
• International Taxation.
Introduction.
Basic U.S. Jurisdictional Tax Principles.
Taxing Rules.
Source Rules.
The Role of Income Tax Treaties.
Filing, Withholding, and Reporting Requirements.
Introduction to U.S. Business Activity in Foreign Countries.
The Foreign Tax Credit.
Intercompany Pricing.
Controlled Foreign Corporations and Related Provisions.
Foreign Currency. International Tax-Free Transactions.
Tax Arbitrage and Economic Substance. Foreign Sales Corporations.
International Boycott and Foreign Bribery Provisions.
Estate and Gift Taxation for Resident and Nonresident Aliens.
Indexes