Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen Burke
Publisher: West Academic Publishing
ISBN: 1634607120
Release Date: 2016-12-24
Genre:

This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised fifth edition reflects developments through September 2016, including proposed rules relating to compensatory profits interests and fee waivers, contributed built-in loss property, sharing of partnership liabilities and disguised sales, basis adjustments under �� 734(b), 743(b) and 755, and � 751(b) distributions.

Taxation of S Corporations in a Nutshell

Author: Douglas Kahn
Publisher: West Academic Publishing
ISBN: 1683282205
Release Date: 2017-02-24
Genre:

The Subchapter S rules are complex. This book describes the basic rules that apply to S corporations and their shareholders with sufficient detail to alert the reader to potential pitfalls. The topics covered include: (1) the qualification requirements for a Subchapter S election, (2) the allocation of tax items among the shareholders, (3) the effect of those allocations on a shareholder's basis in stock and debt, (4) the limitations on the deduction of pass through items, (5) the treatment of corporate distributions, (6) the voluntary and involuntary termination of Subchapter S status, (7) the treatment of the year in which a Subchapter S election is terminated, (8) the limited availability of certain Subchapter S provisions after a Subchapter S election is terminated, and (9) the taxation of an S corporation's passive investment income and built-in gains. The discussion of these issues is supplemented by numerous examples.

Federal Income Taxation of Corporations and Stockholders in a Nutshell

Author: Karen C. Burke
Publisher:
ISBN: 0314288228
Release Date: 2014
Genre: Law

This edition has been completely revised to reflect developments in the Code, regulations, and case law through October 2013. The text focuses on the corporation as a taxable entity and tracks the corporate life cycle from incorporation through complete liquidation. It includes discussion on nonliquidating distributions, redemptions, and stock dividends. It also addresses advanced problems in corporate taxation, such as taxable acquisitions, tax-free reorganizations and corporate divisions, and carryover of corporate tax attributes.

State and Local Taxation and Finance in a Nutshell

Author: M. David Gelfand
Publisher: West Academic
ISBN: 0314183876
Release Date: 2007
Genre: Law

This nutshell is a fully updated summary of state and federal laws that pertain to public finance and taxation. It is a valuable supplement to law school courses on local government law and state and municipal finance, as well as course offerings on these topics in schools of business and public policy. The nutshell places the technical legal rules it considers in the context of the broader public policy issues that those rules raise. It focuses on several past fiscal crises as a catalyst for, as well as a source of, doctrinal changes in these areas of the law."

Practical Guide to S Corporations

Author: Michael Schlesinger
Publisher: CCH
ISBN: 0808017624
Release Date: 2007
Genre: Business & Economics

Practical Guide to S Corporations (Fourth Edition) is written by noted practitioner, author and lecturer Michael Schlesinger. This new Fourth Edition contains extensive discussion of the changes brought about by the Pension Protection Act of 2006 and the Small Business and Work Opportunity Tax Act of 2007. It also covers Treasury regulations related to the Code Sec. 199 manufacturing deduction, as well as cases, rulings and pronouncements issued since the Third Edition.Comprised of fifteen chapters, this book starts by considering the tax advantages of electing S corporation status. The middle chapters, Chapters 2-12, detail the operations of S corporations, discussing statutory requirements, taxpayers who qualify as shareholders, and considerations when converting a C corporation to S status. Chapter 13 provides a comparison of S corporations to other business entities such as limited liability companies, partnerships, and C corporations. Chapter 14 discusses S corporation subsidiaries, and Chapter 15 covers employee stock ownership plans (ESOPs) for S corporations.The book also includes detailed reference material. The Index provides the best access to particular information, but the Contents in Detail can be used as a “second index” for quick entry into the topics. The Appendices supply sample language that can be used in practice, and the Case Table and Finding Lists compile all of the cases, statutes, rulings, and regulations documented throughout the chapters.S corporations are the most popular business entity type, and this updated CCH resource helps practitioners understand and manage individual S corps election, compliance, tax, planning and life-cycle needs. It explains the merits and limitations of S corps in relation to other entity choices and provides clear and practical guidance. Readers will appreciate the Michael Schlesinger's real-world insights and crystal-clear analysis of even the most complex subjects.

International Taxation in a Nutshell

Author: Richard Doernberg
Publisher: West Academic Publishing
ISBN: 1628105550
Release Date: 2015-12-18
Genre:

This nutshell not only addresses the fundamentals of U.S. international taxation, but it also offers insight into tax planning considerations. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In the truly global economy in which we live, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. Building on both academic and private sector careers, the author has used his experience to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts, including the most recent developments.

State and Local Taxation

Author: Charles W. Swenson
Publisher: J. Ross Publishing
ISBN: 1932159177
Release Date: 2003-06-01
Genre: Business & Economics

Companies can easily become ensnared in the tangle oftaxes imposed by the many governments involved in cross-border transactions. If you want to avoid significant taxhazards and protect cash flow and capital, stock valueand executive compensation in the form of stock optionsor just plain save money, you need to read State andLocal ......

Mastering Corporate Tax

Author: Reginald Mombrun
Publisher:
ISBN: 153100802X
Release Date: 2017-10-20
Genre: Corporate reorganizations

This book explains material students encounter in law school corporate tax courses. Its many examples reinforce the authors' explanation of the relevant Code sections, administrative interpretations, and case law. Topics covered include formation, taxable income, earnings and profits, dividends, redemptions, liquidations, reorganizations, and S corporations.

Fixing U S International Taxation

Author: Daniel N. Shaviro
Publisher: Oxford University Press
ISBN: 9780190224776
Release Date: 2014-02-05
Genre: Law

International tax rules, which determine how countries tax cross-border investment, are increasingly important with the rise of globalization, but the modern U.S. rules, even more than those in most other countries, are widely recognized as dysfunctional. The existing debate over how to reform the U.S. tax rules is stuck in a sterile dialectic, in which ostensibly the only permissible choices are worldwide or residence-based taxation of U.S. companies with the allowance of foreign tax credits, versus outright exemption of the companies' foreign source income. In Fixing U.S. International Taxation, Daniel N. Shaviro explains why neither of these solutions addresses the fundamental problem at hand, and he proposes a new reformulation of the existing framework from first principles. He shows that existing international tax policy frameworks are misguided insofar as they treat "double taxation" and "double non-taxation" as the key issues, conflate the distinct questions of what tax rate to impose on foreign source income and how to treat foreign taxes, and use simplistic single-bullet global welfare norms in lieu of a comprehensive analysis. Drawing on tools that are familiar from public economics and trade policy, but that have been under-utilized in the international tax realm, Shaviro offers a better analysis that not only reshapes our understanding of the underlying issues, but might point the way to substantially improving the prevailing rules, both in the U.S. and around the world.

Taxpayer s Comprehensive Guide to LLCs and S Corps

Author: Jason Watson
Publisher: Watson CPA Group
ISBN: 9780990763291
Release Date: 2014-09-03
Genre: Business & Economics

How can I avoid self-employment taxes? This simple question was the inspiration for creating an article describing the benefits of an S Corporation. That original article, which was about four pages long, quickly became a series of KnowledgeBase articles on the Watson CPA Group website. The articles touched on basic topics such as how to elect S Corp status, payroll, reasonable salary determination, retirement planning, health care, fringe benefits and liability protection. Those broad topics demanded much more information, both horizontally by spanning into more related issues, and vertically by digging deeper into the granular yet riveting levels of the tax code. The articles were grouped and relabeled as the Taxpayer’s Comprehensive Guide to LLCs and S Corps which grew to 39 pages in its first edition. Time marched on, and more information was added to the first edition such as expanded retirement planning concerns, health care options after the Affordable Care Act and business valuations including exit strategies. Boom, we now had our second edition at over 100 pages. At that point it was suggested by some clients and colleagues to convert the PDF into an eBook as well as paperback. So here we are.. Each week we receive several phone calls and emails from small business owners across the country who have read our Taxpayer’s Comprehensive Guide to LLCs and S Corps and praised the wealth of information. Regardless of your current situation, whether you are considering starting your own business or entertaining a contracting gig, or you are an experienced business owner, the contents of this book are for you. This book will show you how to reduce your self-employment taxes through an S Corporation election and how to use your corporation to your retirement and fringe benefit advantage. You will also learn the operational considerations of an S Corp plus the 185 reasons you should NOT elect S Corp status. Want to buy or sell a business? That’s in here too. This book is written with the general taxpayer in mind. Too many resources simply regurgitate complex tax code without explanation. While in some cases tax code and court opinions are duplicated verbatim because of the precise words, this book strives to explain many technical concepts in layperson terms with some added humor and opinions. We believe you will find this book educational as well as amusing.

Tax Procedure and Tax Fraud in a Nutshell

Author: Camilla E. Watson
Publisher: West Group
ISBN: 0314146466
Release Date: 2006-01-01
Genre: Law

Reliable source on tax procedure and tax fraud helps bridge the gap between understanding "substantive" code provisions and preparing to represent a taxpayer in an Internal Revenue Service (IRS) dispute. Coverage includes IRS and treasury rulemaking; confidentiality and disclosure; audits and administrative appeals; statute of limitations; litigation considerations; penalties and collection process; liability; investigation; and tax crimes.

Principles of Corporate Taxation

Author: Douglas A. Kahn
Publisher: West Academic Publishing
ISBN: 0314184961
Release Date: 2010
Genre: Law

The book is not organized according to the chronological life of a corporation. Instead, the book begins by examining the tax treatment of a withdrawal of property from an existing corporation. The reason for choosing that organization is that the concepts embodied in such topics as dividends, earnings and profits, and stock redemptions are the fundamental building blocks on which the more complex provisions of corporate taxation rest. The authors explain the technical operation of the various Code provisions and provide numerous examples illustrating how they are applied and how several provisions must be read in concert with each other.

Federal Estate and Gift Taxation in a Nutshell

Author: John K. McNulty
Publisher:
ISBN: STANFORD:36105061117078
Release Date: 1994-01-01
Genre: Generation-skipping transfer tax

Wealth Transfer Taxation; Constitutionality; The Federal Estate Tax, Gift Tax and Generation-Skipping Transfer Tax Outlined; Unification of Transfer Taxes; Gratuitous Transfers; Transfers During Life; Donative Intent; Consideration; Property; Transfer; Inclusion in the Gross Estate; Alternative Valuation Date; Liability for Tax; Incomplete Transfers; Transfers in Contemplation of Death; Retained Interests or Powers; Revocable Transfers; Special Valuation Rules and "Estate Freezes; " Jointly-Owned Property; Community Property; Property Settlements; Life Insurance; Annuities; Employee Death Benefits; Powers of Appointment; Inclusion; Valuation; Exemptions; Exclusions; Future Interests; Deductions (Charitable, etc.); Marital Deduction; Split Gifts; Unified Credit; International; Estate Planning; Reforms and Fundamental Alternatives.