Preface |
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xiv | |
Chapter 1 Tax Research |
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1-1 | (1) |
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1-2 | (1) |
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Steps in the Tax Research Process |
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1-3 | (1) |
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Importance of the Facts to the Tax Consequences |
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1-5 | (1) |
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Creating a Factual Situation Favorable to the Taxpayer |
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1-6 | (1) |
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1-7 | (1) |
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1-7 | (1) |
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The Internal Revenue Code |
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1-8 | (1) |
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1-9 | (1) |
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Administrative Pronouncements |
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1-11 | (1) |
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1-14 | (1) |
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1-24 | (1) |
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1-24 | (1) |
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1-25 | (1) |
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The Internet as a Research Tool |
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1-26 | (1) |
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1-27 | (1) |
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1-28 | (1) |
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Noncommercial Internet Services |
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1-28 | (1) |
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1-28 | (1) |
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1-30 | (1) |
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Professional Guidelines for Tax Services |
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1-30 | (1) |
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Treasury Department Circular 230 |
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1-30 | (1) |
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AICPA's Statements on Tax Standards |
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1-31 | (1) |
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Sample Work Papers and Client Letter |
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1-34 | (1) |
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1-34 | (1) |
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1-34 | (1) |
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1-35 | (1) |
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1-38 | (1) |
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1-38 | (1) |
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1-39 | (1) |
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1-39 | (1) |
Chapter 2 Corporate Formations And Capital Structure |
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2-1 | (1) |
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Organization Forms Available |
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2-2 | (1) |
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2-2 | (1) |
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2-3 | (1) |
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2-5 | (1) |
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Limited Liability Companies |
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2-8 | (1) |
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Limited Liability Partnerships |
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2-8 | (1) |
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Check-the-Box Regulations |
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2-8 | (1) |
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Legal Requirements and Tax Considerations Related to Forming a Corporation |
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2-9 | (1) |
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2-9 | (1) |
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2-9 | (1) |
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Section 351: Deferring Gain or Loss Upon Incorporation |
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2-12 | (1) |
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2-12 | (1) |
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2-13 | (1) |
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2-16 | (1) |
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Effect of Sec. 351 on the Transferors |
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2-16 | (1) |
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Tax Consequences to Transferee Corporation |
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2-20 | (1) |
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Assumption of the Transferor's Liabilities |
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2-22 | (1) |
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Other Considerations in a Sec. 351 Exchange |
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2-25 | (1) |
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Choice of Capital Structure |
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2-27 | (1) |
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Characterization of Obligations as Debt or Equity |
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2-27 | (1) |
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2-28 | (1) |
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2-29 | (1) |
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Capital Contributions by Shareholders |
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2-29 | (1) |
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Capital Contributions by Nonshareholders |
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2-31 | (1) |
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Worthlessness of Stock or Debt Obligations |
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2-32 | (1) |
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2-32 | (1) |
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Unsecured Debt Obligations |
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2-33 | (1) |
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Tax Planning Considerations |
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2-34 | (1) |
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2-34 | (1) |
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Compliance and Procedural Considerations |
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2-36 | (1) |
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Reporting Requirements Under Sec. 351 |
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2-36 | (1) |
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2-37 | (1) |
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2-37 | (1) |
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Issue Identification Questions |
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2-38 | (1) |
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2-38 | (1) |
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2-43 | (1) |
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2-44 | (1) |
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2-44 | (1) |
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2-45 | (1) |
Chapter 3 The Corporate Income Tax |
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3-1 | (1) |
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3-2 | (1) |
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Choosing a Calendar or Fiscal Year |
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3-2 | (1) |
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3-4 | (1) |
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Determining a Corporation's Taxable Income |
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3-5 | (1) |
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Sales and Exchanges of Property |
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3-6 | (1) |
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3-8 | (1) |
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3-14 | (1) |
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Exceptions for Closely Held Corporations |
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3-21 | (1) |
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Computing a Corporation's Income Tax Liability |
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3-22 | (1) |
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3-23 | (1) |
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Personal Service Corporations |
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3-24 | (1) |
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Controlled Groups of Corporations |
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3-24 | (1) |
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Why Special Rules Are Needed |
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3-24 | (1) |
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What Is a Controlled Group? |
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3-25 | (1) |
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Application of the Controlled Group Test |
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3-28 | (1) |
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Special Rules Applying to Controlled Groups |
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3-29 | (1) |
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3-29 | (1) |
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Tax Planning Considerations |
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3-31 | (1) |
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Compensation Planning for Shareholder-Employees |
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3-31 | (1) |
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Special Election to Allocate Reduced Tax Rate Benefits |
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3-32 | (1) |
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Using NOL Carryovers and Carrybacks |
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3-34 | (1) |
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Compliance and Procedural Considerations |
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3-35 | (1) |
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3-35 | (1) |
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Requirements for Filing and Paying Taxes |
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3-38 | (1) |
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When the Return Must Be Filed |
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3-38 | (1) |
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3-39 | (1) |
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Financial Statement Implications |
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3-43 | (1) |
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Scope, Objectives, and Principles of ASC 740 |
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3-44 | (1) |
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3-44 | (1) |
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Deferred Tax Assets and the Valuation Allowance |
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3-44 | (1) |
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Accounting for Uncertain Tax Positions |
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3-45 | (1) |
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Balance Sheet Classification |
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3-46 | (1) |
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3-47 | (1) |
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Comprehensive Example - Year 1 |
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3-47 | (1) |
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Comprehensive Example - Year 2 |
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3-50 | (1) |
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3-54 | (1) |
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3-54 | (1) |
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3-54 | (1) |
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Issue Identification Questions |
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3-55 | (1) |
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3-56 | (1) |
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3-64 | (1) |
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3-65 | (1) |
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Tax Form/Return Preparation Problems |
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3-65 | (1) |
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3-70 | (1) |
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3-71 | (1) |
Chapter 4 Corporate Nonliquidating Distributions |
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4-1 | (1) |
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Nonliquidating Distributions in General |
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4-2 | (1) |
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Earnings and Profits (E&P) |
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4-3 | (1) |
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Current Earnings and Profits |
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4-3 | (1) |
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Distinction Between Current and Accumulated E&P |
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4-6 | (1) |
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Nonliquidating Property Distributions |
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4-8 | (1) |
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Consequences of Nonliquidating Property Distributions to the Shareholders |
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4-8 | (1) |
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Consequences of Property Distributions to the Distributing Corporation |
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4-9 | (1) |
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4-11 | (1) |
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Stock Dividends and Stock Rights |
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4-13 | (1) |
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Nontaxable Stock Dividends |
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4-14 | (1) |
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4-14 | (1) |
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Effect of Nontaxable Stock Dividends on the Distributing Corporation |
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4-15 | (1) |
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Taxable Stock Dividends and Stock Rights |
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4-15 | (1) |
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4-16 | (1) |
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Tax Consequences of the Redemption to the Shareholder |
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4-17 | (1) |
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4-18 | (1) |
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Substantially Disproportionate Redemptions |
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4-20 | (1) |
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Complete Termination of the Shareholder's Interest |
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4-21 | (1) |
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Redemptions Not Essentially Equivalent to a Dividend |
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4-23 | (1) |
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4-23 | (1) |
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Redemptions to Pay Death Taxes |
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4-25 | (1) |
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Effect of Redemptions on the Distributing Corporation |
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4-26 | (1) |
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4-27 | (1) |
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4-28 | (1) |
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Dispositions of Sec. 306 Stock |
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4-28 | (1) |
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Redemptions of Sec. 306 Stock |
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4-29 | (1) |
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Exceptions to Sec. 306 Treatment |
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4-30 | (1) |
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Stock Redemptions by Related Corporations |
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4-30 | (1) |
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Brother-Sister Corporations |
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4-30 | (1) |
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Parent-Subsidiary Corporations |
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4-32 | (1) |
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Tax Planning Considerations |
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4-33 | (1) |
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Avoiding Unreasonable Compensation |
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4-33 | (1) |
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4-34 | (1) |
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4-35 | (1) |
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Compliance and Procedural Considerations |
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4-36 | (1) |
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Corporate Reporting of Nondividend Distributions |
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4-36 | (1) |
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Agreement to Terminate Interest Under Sec. 302(b)(3) |
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4-36 | (1) |
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4-37 | (1) |
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4-37 | (1) |
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Issue Identification Questions |
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4-38 | (1) |
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4-39 | (1) |
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4-45 | (1) |
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4-46 | (1) |
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4-46 | (1) |
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4-47 | (1) |
Chapter 5 Other Corporate Tax Levies |
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5-1 | (1) |
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The Alternative Minimum Tax |
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5-2 | (1) |
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5-2 | (1) |
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Exemption from the AMT for Small Corporations and First-Year Corporations |
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5-3 | (1) |
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5-5 | (1) |
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5-5 | (1) |
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Adjusted Current Earnings (ACE) Adjustment |
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5-9 | (1) |
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5-12 | (1) |
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5-13 | (1) |
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Personal Holding Company Tax |
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5-14 | (1) |
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Personal Holding Company Defined |
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5-15 | (1) |
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Stock Ownership Requirement |
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5-15 | (1) |
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Passive Income Requirement |
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5-15 | (1) |
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5-19 | (1) |
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Avoiding the PHC Designation and Tax Liability by Making Dividend Distributions |
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5-21 | (1) |
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5-22 | (1) |
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5-23 | (1) |
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Corporations Subject to the Penalty Tax |
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5-23 | (1) |
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Proving a Tax-Avoidance Purpose |
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5-24 | (1) |
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Evidence Concerning the Reasonableness of an Earnings Accumulation |
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5-25 | (1) |
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Calculating the Accumulated Earnings Tax |
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5-29 | (1) |
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5-32 | (1) |
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Tax Planning Considerations |
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5-33 | (1) |
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5-33 | (1) |
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Eliminating the ACE Adjustment |
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5-34 | (1) |
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5-34 | (1) |
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Avoiding the Personal Holding Company Tax |
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5-35 | (1) |
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Avoiding the Accumulated Earnings Tax |
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5-35 | (1) |
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Compliance and Procedural Considerations |
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5-36 | (1) |
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5-36 | (1) |
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Personal Holding Company Tax |
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5-36 | (1) |
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5-36 | (1) |
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Financial Statement Implications |
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5-37 | (1) |
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5-37 | (1) |
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5-38 | (1) |
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5-38 | (1) |
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Issue Identification Questions |
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5-41 | (1) |
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5-41 | (1) |
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5-49 | (1) |
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5-50 | (1) |
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Tax Form/Return Preparation Problem |
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5-50 | (1) |
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5-51 | (1) |
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5-51 | (1) |
Chapter 6 Corporate Liquidating Distributions |
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6-1 | (1) |
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Overview of Corporate Liquidations |
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6-2 | (1) |
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6-2 | (1) |
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6-3 | (1) |
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Definition of a Complete Liquidation |
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6-3 | (1) |
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General Liquidation Rules |
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6-5 | (1) |
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Effects of Liquidating on the Shareholders |
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6-5 | (1) |
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Effects of Liquidating on the Liquidating Corporation |
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6-6 | (1) |
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Liquidation of a Controlled Subsidiary |
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6-10 | (1) |
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6-10 | (1) |
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6-11 | (1) |
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Effects of Liquidating on the Shareholders |
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6-12 | (1) |
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Effects of Liquidating on the Subsidiary Corporation |
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6-13 | (1) |
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6-15 | (1) |
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Pertaining to Shareholders |
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6-15 | (1) |
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Pertaining to the Liquidating Corporation |
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6-16 | (1) |
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Recognition of Gain or Loss When Property Is Distributed in Retirement of Debt |
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6-17 | (1) |
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6-17 | (1) |
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Satisfaction of the Subsidiary's Debt Obligations |
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6-17 | (1) |
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Tax Planning Considerations |
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6-18 | (1) |
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Timing the Liquidation Transaction |
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6-18 | (1) |
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Recognition of Ordinary Losses When a Liquidation Occurs |
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6-19 | (1) |
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Obtaining 80% Ownership to Achieve Sec. 332 Benefits |
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6-19 | (1) |
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Avoiding Sec. 332 to Recognize Losses |
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6-20 | (1) |
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Compliance and Procedural Considerations |
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6-20 | (1) |
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General Liquidation Procedures |
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6-20 | (326) |
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332 | |
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6-21 | (1) |
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6-21 | (1) |
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6-21 | (1) |
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6-21 | (1) |
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Issue Identification Questions |
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6-23 | (1) |
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6-24 | (1) |
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6-30 | (1) |
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6-31 | (1) |
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6-32 | (1) |
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6-33 | (1) |
Chapter 7 Corporate Acquisitions And Reorganizations |
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7-1 | (1) |
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Taxable Acquisition Transactions |
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7-2 | (1) |
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7-2 | (1) |
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7-4 | (1) |
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Comparison of Taxable and Nontaxable Acquisitions |
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7-10 | (1) |
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Taxable and Nontaxable Asset Acquisitions |
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7-10 | (1) |
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Comparison of Taxable and Nontaxable Stock Acquisitions |
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7-11 | (1) |
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Types of Reorganizations and Their Tax Consequences |
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7-14 | (1) |
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The Target or Transferor Corporation |
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7-14 | (1) |
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The Acquiring or Transferee Corporation |
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7-15 | (1) |
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Shareholders and Security Holders |
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7-16 | (1) |
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Acquisitive Reorganizations |
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7-19 | (1) |
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7-19 | (1) |
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7-25 | (1) |
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7-28 | (1) |
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7-29 | (1) |
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7-33 | (1) |
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7-33 | (1) |
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Divisive Type D Reorganization |
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7-33 | (1) |
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Divisive Type G Reorganization |
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7-38 | (1) |
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7-38 | (1) |
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7-38 | (1) |
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7-40 | (1) |
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Judicial Restrictions on the Use of Corporate Reorganizations |
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7-40 | (1) |
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7-41 | (1) |
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Continuity of Business Enterprise |
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7-41 | (1) |
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Business Purpose Requirement |
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7-42 | (1) |
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Step Transaction Doctrine |
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7-42 | (1) |
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7-43 | (1) |
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Assumption of Tax Attributes |
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7-43 | (1) |
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Limitation on Use of Tax Attributes |
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7-43 | (1) |
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Tax Planning Considerations |
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7-46 | (1) |
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Why Use a Reorganization Instead of a Taxable Transaction? |
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7-46 | (1) |
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Avoiding the Reorganization Provisions |
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7-47 | (1) |
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Compliance and Procedural Considerations |
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7-47 | (1) |
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|
338 | |
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7-47 | (1) |
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7-47 | (1) |
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Party to a Reorganization |
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7-48 | (1) |
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7-48 | (1) |
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Financial Statement Implications |
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7-48 | (1) |
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Taxable Asset Acquisition |
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7-48 | (1) |
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Nontaxable Asset Acquisition |
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7-49 | (1) |
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7-50 | (1) |
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7-50 | (1) |
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7-51 | (1) |
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7-51 | (1) |
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7-51 | (1) |
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Issue Identification Questions |
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7-52 | (1) |
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7-53 | (1) |
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7-61 | (1) |
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7-62 | (1) |
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7-63 | (1) |
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7-63 | (1) |
Chapter 8 Consolidated Tax Returns |
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8-1 | (1) |
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Definition of an Affiliated Group |
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8-2 | (1) |
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8-2 | (1) |
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Comparison with Controlled Group Definitions |
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8-4 | (1) |
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Consolidated Tax Return Election |
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8-4 | (1) |
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Consolidated Return Regulations |
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8-4 | (1) |
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Termination of Consolidated Tax Return Filing |
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8-5 | (1) |
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Consolidated Taxable Income |
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8-6 | (1) |
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Accounting Periods and Methods |
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8-6 | (1) |
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Income Included in the Consolidated Tax Return |
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8-6 | (1) |
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Calculation of Consolidated Taxable Income and Tax |
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8-8 | (1) |
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Intercompany Transactions |
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8-8 | (1) |
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8-8 | (1) |
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Matching and Acceleration Rules |
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8-10 | (1) |
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Applications of Matching and Acceleration Rules |
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8-12 | (1) |
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Relevance of Matching and Acceleration Rules |
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8-18 | (1) |
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Items Computed on a Consolidated Basis |
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8-18 | (1) |
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Charitable Contribution Deduction |
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8-19 | (1) |
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Net Sec. 1231 Gain or Loss |
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8-19 | (1) |
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8-19 | (1) |
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Dividends-Received Deduction |
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8-20 | (1) |
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U.S. Production Activities Deduction |
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8-22 | (1) |
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8-24 | (1) |
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Corporate Alternative Minimum Tax |
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8-24 | (1) |
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8-25 | (1) |
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8-26 | (1) |
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Net Operating Losses (NOLs) |
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8-27 | (1) |
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8-27 | (1) |
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Carrybacks and Carryovers of Consolidated NOLs |
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8-28 | (1) |
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8-30 | (1) |
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8-34 | (1) |
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Tiering Up of Stock Basis Adjustments |
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8-35 | (1) |
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8-36 | (1) |
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Tax Planning Considerations |
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8-36 | (1) |
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Advantages of Filing a Consolidated Tax Return |
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8-36 | (1) |
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Disadvantages of Filing a Consolidated Tax Return |
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8-37 | (1) |
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Compliance and Procedural Considerations |
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8-37 | (1) |
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The Basic Election and Return |
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8-37 | (1) |
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Parent Corporation as Agent for the Consolidated Group |
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8-38 | (1) |
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Separate Entity Treatment of Intercompany Transactions |
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8-39 | (1) |
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8-39 | (1) |
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Financial Statement Implications |
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8-39 | (1) |
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Intercompany Transactions |
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8-39 | (1) |
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8-41 | (1) |
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8-42 | (1) |
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8-42 | (1) |
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Issue Identification Questions |
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8-43 | (1) |
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8-44 | (1) |
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8-52 | (1) |
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8-53 | (1) |
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Tax Form/Return Preparation Problem |
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8-53 | (1) |
|
|
8-54 | (1) |
|
|
8-55 | (1) |
Chapter 9 Partnership Formation And Operation |
|
9-1 | (1) |
|
Definition of a Partnership |
|
|
9-2 | (1) |
|
General and Limited Partnerships |
|
|
9-2 | (1) |
|
Overview of Taxation of Partnership Income |
|
|
9-4 | (1) |
|
Partnership Profits and Losses |
|
|
9-4 | (1) |
|
|
9-4 | (1) |
|
Partnership Distributions |
|
|
9-5 | (1) |
|
Tax Implications of Formation of a Partnership |
|
|
9-5 | (1) |
|
|
9-6 | (1) |
|
|
9-10 | (1) |
|
Organizational and Syndication Expenditures |
|
|
9-12 | (1) |
|
|
9-12 | (1) |
|
|
9-12 | (1) |
|
Other Partnership Elections |
|
|
9-15 | (1) |
|
Partnership Reporting of Income |
|
|
9-16 | (1) |
|
Partnership Taxable Income |
|
|
9-16 | (1) |
|
|
9-16 | (1) |
|
Partnership Ordinary Income |
|
|
9-17 | (1) |
|
U.S. Production Activities Deduction |
|
|
9-17 | (1) |
|
Partner Reporting of Income |
|
|
9-18 | (1) |
|
Partner's Distributive Share |
|
|
9-18 | (1) |
|
|
9-19 | (1) |
|
Basis for Partnership Interest |
|
|
9-21 | (1) |
|
|
9-21 | (1) |
|
|
9-21 | (1) |
|
|
9-24 | (1) |
|
|
9-26 | (1) |
|
|
9-26 | (1) |
|
Passive Activity Limitations |
|
|
9-26 | (1) |
|
Transactions Between a Partner and the Partnership |
|
|
9-27 | (1) |
|
|
9-27 | (1) |
|
|
9-28 | (1) |
|
|
9-30 | (1) |
|
|
9-30 | (1) |
|
Donor-Donee Allocations of Income |
|
|
9-30 | (1) |
|
Tax Planning Considerations |
|
|
9-31 | (1) |
|
Timing of Loss Recognition |
|
|
9-31 | (1) |
|
Compliance and Procedural Considerations |
|
|
9-32 | (1) |
|
Reporting to the IRS and the Partners |
|
|
9-32 | (1) |
|
|
9-33 | (1) |
|
|
9-34 | (1) |
|
|
9-34 | (1) |
|
Issue Identification Questions |
|
|
9-35 | (1) |
|
|
9-36 | (1) |
|
|
9-44 | (1) |
|
|
9-45 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
9-46 | (1) |
|
|
9-50 | (1) |
|
|
9-51 | (1) |
Chapter 10 Special Partnership Issues |
|
10-1 | (1) |
|
Nonliquidating Distributions |
|
|
10-2 | (1) |
|
|
10-2 | (1) |
|
Basis Effects of Distributions |
|
|
10-4 | (1) |
|
Holding Period and Character of Distributed Property |
|
|
10-7 | (1) |
|
Nonliquidating Distributions with Sec. 751 |
|
|
10-7 | (1) |
|
Section 751 Assets Defined |
|
|
10-7 | (1) |
|
Exchange of Sec. 751 Assets and Other Property |
|
|
10-9 | (1) |
|
Liquidating or Selling a Partnership Interest |
|
|
10-11 | (1) |
|
Liquidating Distributions |
|
|
10-12 | (1) |
|
Sale of a Partnership Interest |
|
|
10-16 | (1) |
|
Other Partnership Termination Issues |
|
|
10-19 | (1) |
|
Retirement or Death of a Partner |
|
|
10-19 | (1) |
|
Exchange of a Partnership Interest |
|
|
10-20 | (1) |
|
Income Recognition and Transfers of a Partnership Interest |
|
|
10-22 | (1) |
|
Termination of a Partnership |
|
|
10-22 | (1) |
|
Mergers and Consolidations |
|
|
10-25 | (1) |
|
Division of a Partnership |
|
|
10-25 | (1) |
|
Optional and Mandatory Basis Adjustments |
|
|
10-26 | (1) |
|
|
10-26 | (1) |
|
Adjustments on Distributions |
|
|
10-28 | (1) |
|
Special Forms of Partnerships |
|
|
10-29 | (1) |
|
Tax Shelters and Limited Partnerships |
|
|
10-29 | (1) |
|
Publicly Traded Partnerships |
|
|
10-29 | (1) |
|
Limited Liability Companies |
|
|
10-30 | (1) |
|
Limited Liability Partnerships |
|
|
10-31 | (1) |
|
Limited Liability Limited Partnership |
|
|
10-31 | (1) |
|
Electing Large Partnerships |
|
|
10-32 | (1) |
|
Tax Planning Considerations |
|
|
10-35 | (1) |
|
Liquidating Distribution or Sale to Partners |
|
|
10-35 | (1) |
|
|
10-35 | (1) |
|
|
10-35 | (1) |
|
Issue Identification Questions |
|
|
10-36 | (1) |
|
|
10-37 | (1) |
|
|
10-47 | (1) |
|
|
10-48 | (1) |
|
|
10-49 | (1) |
|
|
10-50 | (1) |
Chapter 11 Corporations |
|
11-1 | (1) |
|
Should an S Election Be Made? |
|
|
11-3 | (1) |
|
Advantages of S Corporation Treatment |
|
|
11-3 | (1) |
|
Disadvantages of S Corporation Treatment |
|
|
11-3 | (1) |
|
S Corporation Requirements |
|
|
11-4 | (1) |
|
Shareholder-Related Requirements |
|
|
11-4 | (1) |
|
Corporation-Related Requirements |
|
|
11-5 | (1) |
|
Election of S Corporation Status |
|
|
11-7 | (1) |
|
|
11-8 | (1) |
|
Termination of the Election |
|
|
11-9 | (1) |
|
|
11-13 | (1) |
|
|
11-13 | (1) |
|
Accounting Method Elections |
|
|
11-14 | (1) |
|
Ordinary Income or Loss and Separately Stated Items |
|
|
11-14 | (1) |
|
U.S. Production Activities Deduction |
|
|
11-16 | (1) |
|
Special S Corporation Taxes |
|
|
11-16 | (1) |
|
Taxation of the Shareholder |
|
|
11-19 | (1) |
|
Income Allocation Procedures |
|
|
11-19 | (1) |
|
Loss and Deduction Pass-Through to Shareholders |
|
|
11-20 | (1) |
|
|
11-24 | (1) |
|
|
11-24 | (1) |
|
Basis Adjustments to S Corporation Stock |
|
|
11-24 | (1) |
|
Basis Adjustments to Shareholder Debt |
|
|
11-25 | (1) |
|
S Corporation Distributions |
|
|
11-27 | (1) |
|
Corporations Having No Earnings and Profits |
|
|
11-27 | (1) |
|
Corporations Having Accumulated Earnings and Profits |
|
|
11-28 | (1) |
|
|
11-32 | (1) |
|
Tax Preference Items and Other AMT Adjustments |
|
|
11-33 | (1) |
|
Transactions Involving Shareholders and Other Related Parties |
|
|
11-33 | (1) |
|
Fringe Benefits Paid to a Shareholder-Employee |
|
|
11-33 | (1) |
|
Tax Planning Considerations |
|
|
11-34 | (1) |
|
Election to Allocate Income Based on the S Corporation's Accounting Methods |
|
|
11-34 | (1) |
|
Increasing the Benefits from S Corporation Losses |
|
|
11-35 | (1) |
|
Passive Income Requirements |
|
|
11-36 | (1) |
|
Compliance and Procedural Considerations |
|
|
11-37 | (1) |
|
|
11-37 | (1) |
|
Filing the Corporate Tax Return |
|
|
11-37 | (1) |
|
|
11-38 | (1) |
|
|
11-39 | (1) |
|
Sample S Corporation Tax Return |
|
|
11-39 | (1) |
|
|
11-40 | (1) |
|
|
11-40 | (1) |
|
Issue Identification Questions |
|
|
11-41 | (1) |
|
|
11-41 | (1) |
|
|
11-47 | (1) |
|
|
11-49 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
11-50 | (1) |
|
|
11-52 | (1) |
|
|
11-53 | (1) |
Chapter 12 The Gift Tax |
|
12-1 | (1) |
|
The Unified Transfer Tax System |
|
|
12-2 | (1) |
|
History and Purpose of Transfer Taxes |
|
|
12-2 | (1) |
|
|
12-3 | (1) |
|
Impact of Taxable Gifts on Death Tax Base |
|
|
12-3 | (1) |
|
|
12-3 | (1) |
|
|
12-4 | (1) |
|
|
12-4 | (1) |
|
Exclusions and Deductions |
|
|
12-4 | (1) |
|
|
12-4 | (1) |
|
Cumulative Nature of Gift Tax |
|
|
12-6 | (1) |
|
|
12-6 | (1) |
|
Transfers Subject to the Gift Tax |
|
|
12-7 | (1) |
|
Transfers for Inadequate Consideration |
|
|
12-7 | (1) |
|
Statutory Exemptions from the Gift Tax |
|
|
12-8 | (1) |
|
Cessation of Donor's Dominion and Control |
|
|
12-10 | (1) |
|
|
12-11 | (1) |
|
Gift Tax Consequences of Certain Transfers |
|
|
12-13 | (1) |
|
|
12-16 | (1) |
|
|
12-16 | (1) |
|
Present Interest Requirement |
|
|
12-16 | (1) |
|
|
12-18 | (1) |
|
|
12-19 | (1) |
|
Charitable Contribution Deduction |
|
|
12-21 | (1) |
|
The Gift-Splitting Election |
|
|
12-22 | (1) |
|
Computation of the Gift Tax Liability |
|
|
12-23 | (1) |
|
Effect of Previous Taxable Gifts |
|
|
12-23 | (1) |
|
|
12-24 | (1) |
|
Comprehensive Illustration |
|
|
12-25 | (1) |
|
Basis Considerations for a Lifetime Giving Plan |
|
|
12-26 | (1) |
|
Property Received by Gift |
|
|
12-26 | (1) |
|
Property Received at Death |
|
|
12-27 | (1) |
|
Below-Market Loans: Gift and Income Tax Consequences |
|
|
12-28 | (1) |
|
|
12-28 | (1) |
|
|
12-28 | (1) |
|
Tax Planning Considerations |
|
|
12-29 | (1) |
|
Tax-Saving Features of Inter Vivos Gifts |
|
|
12-29 | (1) |
|
Negative Aspects of Gifts |
|
|
12-30 | (1) |
|
Compliance and Procedural Considerations |
|
|
12-30 | (1) |
|
|
12-30 | (1) |
|
|
12-31 | (1) |
|
|
12-31 | (1) |
|
|
12-31 | (1) |
|
|
12-32 | (1) |
|
|
12-32 | (1) |
|
|
12-33 | (1) |
|
|
12-33 | (1) |
|
Issue Identification Questions |
|
|
12-34 | (1) |
|
|
12-34 | (1) |
|
|
12-37 | (1) |
|
|
12-38 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
12-38 | (1) |
|
|
12-39 | (1) |
|
|
12-39 | (1) |
Chapter 13 The Estate Tax |
|
13-1 | (1) |
|
|
13-2 | (1) |
|
|
13-2 | (1) |
|
|
13-3 | (1) |
|
Adjusted Taxable Gifts and Tax Base |
|
|
13-4 | (1) |
|
Tentative Tax on Estate Tax Base |
|
|
13-4 | (1) |
|
Reduction for Post-1976 Gift Taxes |
|
|
13-4 | (1) |
|
|
13-5 | (1) |
|
The Gross Estate: Valuation |
|
|
13-6 | (1) |
|
|
13-6 | (1) |
|
|
13-7 | (1) |
|
The Gross Estate: Inclusions |
|
|
13-8 | (1) |
|
Comparison of Gross Estate with Probate Estate |
|
|
13-9 | (1) |
|
Property in Which the Decedent Had an Interest |
|
|
13-9 | (1) |
|
|
13-10 | (1) |
|
|
13-10 | (1) |
|
Annuities and Other Retirement Benefits |
|
|
13-13 | (1) |
|
|
13-14 | (1) |
|
General Powers of Appointment |
|
|
13-15 | (1) |
|
|
13-16 | (1) |
|
|
13-17 | (1) |
|
Recipient Spouse's Interest in QTIP Trust |
|
|
13-17 | (1) |
|
|
13-18 | (1) |
|
Debts and Funeral and Administration Expenses |
|
|
13-18 | (1) |
|
|
13-19 | (1) |
|
Charitable Contribution Deduction |
|
|
13-19 | (1) |
|
|
13-20 | (1) |
|
Computation of Tax Liability |
|
|
13-23 | (1) |
|
Taxable Estate and Tax Base |
|
|
13-23 | (1) |
|
Tentative Tax and Reduction for Post-1976 Gift Taxes |
|
|
13-23 | (1) |
|
|
13-23 | (1) |
|
Portability Between Spouses of Exemption Amount |
|
|
13-24 | (1) |
|
|
13-24 | (1) |
|
Comprehensive Illustration |
|
|
13-25 | (1) |
|
|
13-28 | (1) |
|
Deferral of Payment of Estate Taxes |
|
|
13-28 | (1) |
|
Stock Redemptions to Pay Death Taxes |
|
|
13-29 | (1) |
|
Special Use Valuation of Farm Real Property |
|
|
13-29 | (1) |
|
Generation-Skipping Transfer Tax |
|
|
13-30 | (1) |
|
Tax Planning Considerations |
|
|
13-31 | (1) |
|
|
13-32 | (1) |
|
Use of Exemption Equivalent |
|
|
13-32 | (1) |
|
What Size Marital Deduction Is Best? |
|
|
13-33 | (1) |
|
|
13-33 | (1) |
|
|
13-33 | (1) |
|
Qualifying the Estate for Installment Payments |
|
|
13-34 | (1) |
|
Where to Deduct Administration Expenses |
|
|
13-34 | (1) |
|
Compliance and Procedural Considerations |
|
|
13-35 | (1) |
|
|
13-35 | (1) |
|
|
13-35 | (1) |
|
|
13-35 | (1) |
|
Election of Alternate Valuation Date |
|
|
13-35 | (1) |
|
|
13-36 | (1) |
|
|
13-36 | (1) |
|
Issue Identification Questions |
|
|
13-37 | (1) |
|
|
13-37 | (1) |
|
|
13-41 | (1) |
|
|
13-42 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
13-43 | (1) |
|
|
13-44 | (1) |
|
|
13-45 | (1) |
Chapter 14 Income Taxation Of Trusts And Estates |
|
14-1 | (1) |
|
|
14-2 | (1) |
|
|
14-2 | (1) |
|
|
14-2 | (1) |
|
Reasons for Creating Trusts |
|
|
14-3 | (1) |
|
Basic Principles of Fiduciary Taxation |
|
|
14-3 | (1) |
|
Principles of Fiduciary Accounting |
|
|
14-4 | (1) |
|
The Importance of Identifying Income and Principal |
|
|
14-4 | (1) |
|
Principal and Income: The Uniform Act |
|
|
14-5 | (1) |
|
Categorization of Depreciation |
|
|
14-6 | (1) |
|
Formula for Taxable Income and Tax Liability |
|
|
14-7 | (1) |
|
|
14-7 | (1) |
|
|
14-7 | (1) |
|
|
14-9 | (1) |
|
|
14-9 | (1) |
|
|
14-10 | (1) |
|
U.S. Production Activities Deduction |
|
|
14-10 | (1) |
|
|
14-10 | (1) |
|
|
14-11 | (1) |
|
|
14-11 | (1) |
|
|
14-11 | (1) |
|
Determining a Simple Trust's Taxable Income |
|
|
14-13 | (1) |
|
Allocation of Expenses to Tax-Exempt Income |
|
|
14-14 | (1) |
|
Determination of DNI and the Distribution Deduction |
|
|
14-15 | (1) |
|
Tax Treatment for Beneficiary |
|
|
14-15 | (1) |
|
Shortcut Approach to Proving Correctness of Taxable Income |
|
|
14-16 | (1) |
|
Effect of a Net Operating Loss |
|
|
14-16 | (1) |
|
Effect of a Net Capital Loss |
|
|
14-16 | (1) |
|
Comprehensive Illustration: Determining a Simple Trust's Taxable Income |
|
|
14-17 | (1) |
|
Determining Taxable Income for Complex Trusts and Estates |
|
|
14-19 | (1) |
|
Determination of DNI and the Distribution Deduction |
|
|
14-20 | (1) |
|
Tax Treatment for Beneficiary |
|
|
14-21 | (1) |
|
Effect of a Net Operating Loss |
|
|
14-24 | (1) |
|
Effect of a Net Capital Loss |
|
|
14-24 | (1) |
|
Comprehensive Illustration: Determining a Complex Trust's Taxable Income |
|
|
14-24 | (1) |
|
Income in Respect of a Decedent |
|
|
14-27 | (1) |
|
Definition and Common Examples |
|
|
14-27 | (1) |
|
|
14-28 | (1) |
|
|
14-30 | (1) |
|
|
14-30 | (1) |
|
|
14-31 | (1) |
|
Post-1986 Reversionary Interest Trusts |
|
|
14-31 | (1) |
|
Retention of Administrative Powers |
|
|
14-31 | (1) |
|
Retention of Economic Benefits |
|
|
14-31 | (1) |
|
Control of Others' Enjoyment |
|
|
14-32 | (1) |
|
Tax Planning Considerations |
|
|
14-33 | (1) |
|
|
14-33 | (1) |
|
|
14-33 | (1) |
|
|
14-34 | (1) |
|
Choice of Year-End for Estates |
|
|
14-34 | (1) |
|
Deduction of Administration Expenses |
|
|
14-34 | (1) |
|
Compliance and Procedural Considerations |
|
|
14-35 | (1) |
|
|
14-35 | (1) |
|
Due Date for Return and Tax |
|
|
14-35 | (1) |
|
Documents to Be Furnished to IRS |
|
|
14-35 | (1) |
|
Sample Simple and Complex Trust Returns |
|
|
14-35 | (1) |
|
|
14-36 | (1) |
|
|
14-36 | (1) |
|
Issue Identification Questions |
|
|
14-37 | (1) |
|
|
14-37 | (1) |
|
|
14-40 | (1) |
|
|
14-40 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
14-41 | (1) |
|
|
14-42 | (1) |
|
|
14-43 | (1) |
Chapter 15 Administrative Procedures |
|
15-1 | (1) |
|
Role of the Internal Revenue Service |
|
|
15-2 | (1) |
|
Enforcement and Collection |
|
|
15-2 | (1) |
|
Interpretation of the Statute |
|
|
15-2 | (1) |
|
|
15-3 | (1) |
|
Percentage of Returns Examined |
|
|
15-3 | (1) |
|
Selection of Returns for Audit |
|
|
15-3 | (1) |
|
Disclosure of Uncertain Tax Positions |
|
|
15-5 | (1) |
|
Alternatives for a Taxpayer Whose Return Is Audited |
|
|
15-5 | (1) |
|
|
15-7 | (1) |
|
|
15-7 | (1) |
|
|
15-9 | (1) |
|
Information to Be Included in Taxpayer's Request |
|
|
15-9 | (1) |
|
|
15-10 | (1) |
|
When Rulings Are Desirable |
|
|
15-10 | (1) |
|
|
15-10 | (1) |
|
|
15-10 | (1) |
|
|
15-11 | (1) |
|
Due Dates for Payment of the Tax |
|
|
15-11 | (1) |
|
Interest on Tax Not Timely Paid |
|
|
15-12 | (1) |
|
Failure-to-File and Failure-to-Pay Penalties |
|
|
15-13 | (1) |
|
|
15-15 | (1) |
|
|
15-16 | (1) |
|
|
15-17 | (1) |
|
|
15-17 | (1) |
|
Penalty for Underpaying Estimated Taxes |
|
|
15-18 | (1) |
|
Exceptions to the Penalty |
|
|
15-19 | (1) |
|
Other More Severe Penalties |
|
|
15-20 | (1) |
|
|
15-20 | (1) |
|
Substantial Understatement |
|
|
15-21 | (1) |
|
Transactions without Economic Substance |
|
|
15-22 | (1) |
|
|
15-22 | (1) |
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15-23 | (1) |
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|
15-24 | (1) |
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|
15-24 | (1) |
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Six-Year Rule for Substantial Omissions |
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|
15-24 | (1) |
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|
15-26 | (1) |
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Other Exceptions to Three-Year Rule |
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|
15-26 | (1) |
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|
15-27 | (1) |
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|
15-27 | (1) |
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|
15-27 | (1) |
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|
15-29 | (1) |
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|
15-29 | (1) |
|
Statutory Provisions Concerning Tax Return Preparers |
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|
15-29 | (1) |
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Reportable Transaction Disclosures |
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|
15-30 | (1) |
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15-31 | (1) |
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Statements on Standards for Tax Services |
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15-32 | (1) |
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Tax Accounting and Tax Law |
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|
15-35 | (1) |
|
Accountant-Client Privilege |
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|
15-36 | (1) |
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|
15-37 | (1) |
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|
15-37 | (1) |
|
Issue Identification Questions |
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|
15-38 | (1) |
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|
15-38 | (1) |
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|
15-41 | (1) |
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|
15-41 | (1) |
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|
15-41 | (1) |
|
|
15-41 | (1) |
Chapter 16 U.S. - Taxation Of Foreign-Related Transactions |
|
16-1 | |
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|
16-2 | (1) |
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Taxation of U.S. Citizens and Resident Aliens |
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|
16-3 | (1) |
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|
16-3 | (1) |
|
Foreign-Earned Income Exclusion |
|
|
16-8 | (1) |
|
Taxation of Nonresident Aliens |
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|
16-14 | (1) |
|
Definition of Nonresident Alien |
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|
16-14 | (1) |
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16-15 | (1) |
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|
16-16 | (1) |
|
Taxation of U.S. Businesses Operating Abroad |
|
|
16-18 | (1) |
|
Domestic Subsidiary Corporations |
|
|
16-18 | (1) |
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|
16-18 | (1) |
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|
16-19 | (1) |
|
Controlled Foreign Corporations |
|
|
16-23 | (1) |
|
|
16-31 | (1) |
|
Tax Planning Considerations |
|
|
16-32 | (1) |
|
Deduction Versus Credit for Foreign Taxes |
|
|
16-32 | (1) |
|
Election to Accrue Foreign Taxes |
|
|
16-33 | (1) |
|
Special Earned Income Elections |
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|
16-34 | (1) |
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|
16-35 | (1) |
|
Special Resident Alien Elections |
|
|
16-35 | (1) |
|
Compliance and Procedural Considerations |
|
|
16-36 | (1) |
|
Foreign Operations of U.S. Corporations |
|
|
16-36 | (1) |
|
Reporting the Foreign Tax Credit |
|
|
16-36 | (1) |
|
Reporting the Earned Income Exclusion |
|
|
16-36 | (1) |
|
Filing Requirements for Aliens and Foreign Corporations |
|
|
16-37 | (1) |
|
Financial Statement Implications |
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|
16-38 | (1) |
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|
16-38 | (1) |
|
Deferred Foreign Earnings |
|
|
16-39 | (1) |
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|
16-42 | |
|
|
16-42 | (1) |
|
Issue Identification Questions |
|
|
16-43 | (1) |
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|
16-44 | (1) |
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|
16-48 | (1) |
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|
16-49 | (1) |
|
Tax Form/Return Preparation Problems |
|
|
16-50 | (1) |
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|
16-50 | (1) |
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|
16-51 | |
Appendices |
|
|
Appendix A Tax Research Working Paper File |
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|
A-1 | |
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|
B-1 | |
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|
C-1 | |
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|
D-1 | |
|
Appendix E AICPA Statements on Standards for Tax Services Nos. 1-7 |
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|
E-1 | |
|
Appendix F Comparison of Tax Attributes for C Corporations, Partnerships, and S Corporations |
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|
F-1 | |
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|
G-1 | |
|
Appendix H Actuarial Tables |
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|
H-1 | |
|
Appendix I Index of Code Sections |
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|
I-1 | |
|
Appendix J Index of Treasury Regulations |
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|
J-1 | |
|
Appendix K Index of Government Promulgations |
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|
K-1 | |
|
Appendix L Index of Court Cases |
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|
L-1 | |
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|
M-1 | |