Overview

Offered as an alternative to the authors’ widely used separate texts on corporate and partnership tax, the Sixth Edition of this comprehensive casebook continues its tradition of providing an integrated approach to teaching the “fundamentals” of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, selective discussion of tax policy issues, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the Sixth Edition include: Coverage of all significant C corporation and partnership developments since the last edition, including the impact of the now permanent higher marginal individual tax rates and the 3.8% net investment income tax; new legislation blocking tax-free spin-offs of REITs; final regulations on § 336(e) elections, Type F reorganizations, noncompensatory options, and partnership allocations where interests change during the year; and new proposed regulations on § 355 corporate divisions, partnership liabilities, § 751(b) disproportionate distributions, and disguised payments for services as applied to investment management fee waivers and similar strategies to convert ordinary income to capital gain. Updated and reorganized discussion of the continuity of proprietary interest doctrine in tax-free reorganizations. Integrated materials related to compensating the service partner in a new and fully updated self-standing chapter. Shorter separate chapters on partnership allocations, allocation of partnership liabilities, income-shifting safeguards, partner-partnership property transactions, liquidating distributions, and partnership terminations and mergers. A new case (Canal Corporation v. Commissioner) illustrating a successful IRS attack on the debt-financed distribution gain deferral strategy. Updated discussion of business enterprise tax policy issues, including a new overview of issues affecting U.S. multinational corporations, the latest prospects and options for comprehensive tax reform, and the ongoing debate on taxing partnership “carried interests.” A completely updated chapter on S corporations, incorporating temporary Code provisions made permanent and final regulations on the basis of indebtedness of S corporations to their shareholders, and expanded coverage of employment tax issues affecting S corporation owners who are active in the business.

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9781634596039

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