Sold Out
Book Categories |
Preface | xxiii | |
Acknowledgements | xxv | |
Part 1 | Some Preliminary Matters | |
Chapter 1 | Introduction | 3 |
The Corporate Income Tax-A Double Tax Regime | 3 | |
Computation and Rate Structure for the Tax on Corporate and Shareholder Income | 6 | |
Nonrecognition in the Subchapter C World | 16 | |
Incidence of the Corporate Tax | 17 | |
Chapter 2 | Choice of Form and Entity Classification | 19 |
Introduction | 19 | |
Choice of Business Form | 20 | |
Classification of the Business Entity | 25 | |
Chapter 3 | The Corporate Capital Structure | 33 |
Introduction | 33 | |
Distinguishing Debt from Equity | 35 | |
Losses from Investments in the Corporate Enterprise | 45 | |
Gains from Investment in the Corporate Enterprise | 47 | |
Conclusion | 48 | |
Part 2 | Corporate Formation | |
Chapter 4 | Incorporation and Other Contributions to Capital | 51 |
Introduction | 51 | |
Shareholder Nonrecognition: [section]351 Eligibility Requirements and Underlying Policy | 53 | |
Operation of Shareholder Nonrecognition Rules | 67 | |
Tax Consequences to the Corporation | 74 | |
Contribution vs. Sale | 76 | |
Additional Contributions to Capital | 78 | |
Effect of Liabilities: [section]357 and Related Matters | 81 | |
Examples | 103 | |
Explanations | 105 | |
Part 3 | Corporate Midlife Events | |
Chapter 5 | Nonliquidating Distributions | 117 |
Introduction | 117 | |
Tax Consequences to the Shareholders | 118 | |
Definitions of Earnings and Profits | 127 | |
Special Rules for Corporate Shareholders | 130 | |
Tax Consequences to the Distributing Corporation | 135 | |
Distributions Involving Liabilities | 141 | |
Constructive Dividends | 143 | |
Examples | 144 | |
Explanations | 146 | |
Chapter 6 | Redemption Distributions | 155 |
Introduction | 155 | |
Tax Consequences to Redeemed Shareholders | 157 | |
A Look at Attribution Rules: [section]318 | 166 | |
Special Issues for Corporate Shareholders | 179 | |
Redemptions of Stock to Pay Death Taxes: [section]303 | 180 | |
Redemptions Related to Inter-Shareholder Transfers and Bootstrap Acquisitions | 181 | |
Redemptions by Related Corporations: [section]304 | 189 | |
Tax Consequences to the Corporation | 197 | |
Examples | 198 | |
Explanations | 200 | |
Chapter 7 | Stock Dividends | 209 |
Introduction | 209 | |
Tax Consequences to the Shareholders | 211 | |
Tax Consequences to the Corporation | 220 | |
The Preferred Stock Bailout: [section]306 Stock | 221 | |
Examples | 235 | |
Explanations | 238 | |
Part 4 | Corporate Liquidation and Related Issues | |
Chapter 8 | General Liquidation Rules | 245 |
Introduction | 245 | |
Tax Consequences to Individual Shareholders: [section]331 | 247 | |
Tax Consequences to the Liquidating Corporation: [section]336 | 253 | |
Examples | 259 | |
Explanations | 262 | |
Chapter 9 | Liquidation of Subsidiaries | 271 |
Introduction | 271 | |
Tax Consequences to the Parent Corporation: [section]332 | 272 | |
Tax Consequences to Minority Shareholders: [section]331 | 276 | |
Tax Consequences to the Liquidating Subsidiary: [section]337 | 276 | |
Examples | 280 | |
Explanations | 282 | |
Part 5 | Corporate Acquisitions, Divisions, and Other Corporate Restructuring | |
Subpart A | Taxable Acquisitions | |
Chapter 10 | Taxable Mergers and Acquisitions | 291 |
Introduction | 291 | |
Taxable Asset Acquisitions | 296 | |
Taxable Stock Acquisitions | 303 | |
Stock Acquisitions Treated as Asset Acquisitions: [section]338 | 305 | |
Special Problems Under [section]338: Affiliated Corporations and Consistency Rules | 318 | |
Creative Acquisition Strategies | 328 | |
Examples | 329 | |
Explanations | 332 | |
Subpart B | Tax-Free Reorganizations | |
Chapter 11 | Introduction to Basic Corporate Reorganization Principles | 343 |
Introduction | 343 | |
Categories of Reorganization | 344 | |
Overview and History: Doctrine Underlying Tax-Free Reorganizations | 346 | |
Overview of Corporate Reorganization Tax Consequences | 347 | |
Judicial Glosses on the Statute | 355 | |
Step-Transaction Doctrine | 376 | |
Meaning of "Party to a Reorganization" and "Plan of Reorganization" | 382 | |
Chapter 12 | Acquisitive Reorganizations | 385 |
Introduction | 385 | |
Acquisitive Stock Reorganizations: The Basic Type B Reorganization | 387 | |
Acquisitive Asset Reorganizations: Basic Statutory Mergers and Consolidations | 395 | |
Acquisitive Asset Reorganizations: The Basic Type C Reorganization | 399 | |
Triangular Reorganizations | 406 | |
Nondivisive Type D Reorganizations | 421 | |
Acquisitive Reorganizations in Insolvency: The Type G Reorganization | 422 | |
Overlaps in the Acquisitive Reorganization Definitions | 423 | |
Proposals to Eliminate the Reorganization Definitions | 424 | |
Carryover of Tax Attributes Following Tax-Free Acquisitive Reorganizations | 425 | |
Examples | 427 | |
Explanations | 431 | |
Chapter 13 | Corporate Divisions | 445 |
Introduction | 445 | |
Overview of [section]355 Requirements | 452 | |
A Closer Look at the [section]355 Requirements | 453 | |
Overlap of [section]368(a)(1)(D) and [section]355: Divisive Reorganizations | 466 | |
Tax Consequences to Shareholders and Other Distributees | 466 | |
Tax Consequences to the Corporation | 468 | |
Examples | 474 | |
Explanations | 476 | |
Chapter 14 | Recapitalization and Other Corporate Restructuring | 483 |
Introduction | 483 | |
Recapitalizations: The Type E Reorganization | 485 | |
Mere Change in Identity, Form, or Place: Type F Reorganization | 498 | |
Examples | 499 | |
Explanations | 501 | |
Table of Cases | 507 | |
Table of Internal Revenue Code Sections | 509 | |
Table of Treasury Regulations and Revenue Rulings | 517 | |
Index | 521 |
Login|Complaints|Blog|Games|Digital Media|Souls|Obituary|Contact Us|FAQ
CAN'T FIND WHAT YOU'RE LOOKING FOR? CLICK HERE!!! X
You must be logged in to add to WishlistX
This item is in your Wish ListX
This item is in your CollectionCorporation Taxation: Examples And Explanations
X
This Item is in Your InventoryCorporation Taxation: Examples And Explanations
X
You must be logged in to review the productsX
X
X
Add Corporation Taxation: Examples And Explanations, The two-step method of the Examples & Explanations Series is especially appropriate for the complex and dynamic area of corporate taxation, and this new edition delivers precisely the right information to lead students to a deeper unders, Corporation Taxation: Examples And Explanations to the inventory that you are selling on WonderClubX
X
Add Corporation Taxation: Examples And Explanations, The two-step method of the Examples & Explanations Series is especially appropriate for the complex and dynamic area of corporate taxation, and this new edition delivers precisely the right information to lead students to a deeper unders, Corporation Taxation: Examples And Explanations to your collection on WonderClub |