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Part 1 Introduction to Taxation and Business Entities |
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Chapter 1 Understanding And Working With The Federal Tax Law |
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1 | (1) |
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The Big Picture: Importance of Tax Research |
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1 | (1) |
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2 | (1) |
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2 | (1) |
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2 | (1) |
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3 | (1) |
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4 | (4) |
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8 | (1) |
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Influence of the Internal Revenue Service |
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9 | (2) |
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11 | (2) |
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13 | (1) |
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Reconciling Accounting Concepts |
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13 | (1) |
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Working With The Tax Law--Tax Sources |
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13 | (1) |
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Statutory Sources of the Tax Law |
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14 | (3) |
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Administrative Sources of the Tax Law |
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17 | (3) |
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Judicial Sources of the Tax Law |
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20 | (2) |
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Concept Summary: Federal Judicial System |
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22 | (3) |
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Concept Summary: Judicial Sources |
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25 | (2) |
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Other Sources of the Tax Law |
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27 | (1) |
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Working With The Tax Law--Locating And Using Tax Sources |
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28 | (1) |
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28 | (1) |
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Financial Disclosure Insights: Where Does GAAP Come From? |
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29 | (1) |
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Using Electronic (Online) Tax Services |
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29 | (1) |
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Noncommercial Electronic (Online) Tax Sources |
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30 | (2) |
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Working With The Tax Law--Tax Research |
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32 | (1) |
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32 | (2) |
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Locating the Appropriate Tax Law Sources |
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34 | (1) |
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Assessing the Validity of Tax Law Sources |
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34 | (1) |
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Ethics & Equity: Choosing Cases for Appeal |
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35 | (1) |
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Arriving at the Solution or at Alternative Solutions |
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36 | (1) |
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Communicating Tax Research |
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37 | (1) |
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Working With The Tax Law--Tax Planning |
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38 | (1) |
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38 | (1) |
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Components of Tax Planning |
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38 | (2) |
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40 | (1) |
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Tax Planning--A Practical Application |
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40 | (1) |
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Taxation On The Cpa Examination |
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40 | (1) |
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41 | (1) |
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41 | |
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Chapter 2 The Deduction For Qualified Business Income For Noncorporate Taxpayers |
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1 | (1) |
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The Big Picture: Entrepreneurial Pursuits |
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1 | (1) |
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Tax Treatment Of Various Business Forms |
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2 | (1) |
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2 | (1) |
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3 | (1) |
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3 | (3) |
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Concept Summary: Tax Treatment of Business Forms Compared |
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6 | (1) |
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Global Tax Issues: U.S. Corporate Taxes and International Business Competitiveness |
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7 | (1) |
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Limited Liability Companies |
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7 | (1) |
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The Tax Cuts And Jobs Act (TCJA) Of 2017 And Entity Tax Rates |
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8 | (1) |
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Challenges of Lowering Tax Rates |
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8 | (1) |
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Lowering Tax Rates for Different Business Forms |
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9 | (1) |
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The Deduction For Qualified Business Income |
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10 | (1) |
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10 | (1) |
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The Overall Limitation: Modified Taxable Income |
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10 | (1) |
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Definition of Qualified Business Income |
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11 | (1) |
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Definition of a Qualified Trade or Business |
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11 | (2) |
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Limitations on the QBI Deduction |
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13 | (1) |
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Limitation Based on Wages and Capital Investment |
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14 | (1) |
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Concept Summary: An Overview of the 2021 Qualified Business Income Deduction |
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15 | (3) |
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Limitation for "Specified Services" Businesses |
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18 | (8) |
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Reporting the Qualified Business Income Deduction |
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26 | (1) |
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Aggregation of Qualified Trades and Businesses Under the § 199A Regulations |
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27 | (5) |
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32 | (2) |
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Coordination with Other Rules |
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34 | (1) |
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Considerations for Partnerships and S Corporations |
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35 | (1) |
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Other Items in the § 199A Regulations |
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35 | (1) |
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36 | (1) |
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Corporate versus Noncorporate Forms of Business Organization |
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36 | (1) |
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Optimizing the Deduction for Qualified Business Income |
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37 | (1) |
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Refocus on the Big Picture: Entrepreneurial Pursuits |
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37 | |
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Chapter 3 Corporations: Introduction And Operating Rules |
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1 | (1) |
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The Big Picture: A Halt-Baked ideal |
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1 | (1) |
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An Introduction To The Income Taxation Of Corporations |
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2 | (1) |
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An Overview of Corporate versus Individual Income Tax Treatment |
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2 | (1) |
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Specific Provisions Compared |
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3 | (1) |
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Accounting Periods and Methods |
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4 | (1) |
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5 | (1) |
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Recapture of Depreciation |
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6 | (1) |
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Business Interest Expense Limitation |
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7 | (2) |
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9 | (1) |
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Concept Summary: Special Rules Applicable to Personal Service Corporations (PSCs) |
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9 | (1) |
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10 | (2) |
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Excessive Executive Compensation |
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12 | (1) |
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13 | (1) |
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Deductions Available Only to Corporations |
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13 | (2) |
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Ethics & Equity: Pushing the Envelope on Year-End Planning |
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15 | (2) |
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Concept Summary: Income Taxation of Individuals and Corporations Compared |
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17 | (2) |
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Determining The Corporate Income Tax Liability |
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19 | (1) |
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Corporate Income Tax Rates |
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19 | (1) |
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19 | (1) |
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Restrictions on Corporate Accumulations |
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20 | (1) |
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21 | (1) |
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Filing Requirements for Corporations |
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21 | (1) |
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21 | (1) |
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Schedule M-1 --Reconciliation of Income (Loss) per Books with Income per Return |
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22 | (1) |
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Schedule M-2--Analysis of Unappropriated Retained Earnings per Books |
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23 | (1) |
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Schedule M-3--Net Income (Loss) Reconciliation for Corporations with Total Assets of $10 Million or More |
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23 | (1) |
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Concept Summary: Conceptual Diagram of Schedule M-1 (Form 1120) |
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24 | (2) |
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Effect of Taxes on the Financial Statements |
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26 | (1) |
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27 | (9) |
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36 | (1) |
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36 | (1) |
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Corporate versus Noncorporate Forms of Business Organization |
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36 | (1) |
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Operating the Corporation |
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37 | (2) |
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Refocus on the Big Picture: Cooked to Perfection |
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39 | |
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Chapter 4 Corporations: Organization And Capital Structure |
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1 | (1) |
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The Big Picture: The Vehicle for Business Growth Is the Corporate Form |
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1 | (1) |
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Organization Of And Transfers To Controlled Corporations |
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2 | (1) |
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Section 351 Rationale and General Rules |
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2 | (1) |
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Global Tax Issues: Tax Reform Adds a New Wrinkle to the Choice of Organizational Form When Operating Overseas |
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3 | (2) |
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Concept Summary: Shareholder Consequences: Taxable Corporate Formation versus Tax-Deferred § 351 Transaction |
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5 | (1) |
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5 | (1) |
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6 | (1) |
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Control of the Corporation |
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6 | (4) |
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Basis Determination and Related Issues |
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10 | (1) |
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Concept Summary: Tax Consequences to the Shareholders and Corporation: With and Without the Application of § 351 (Based on the Facts of Example 16) |
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11 | (3) |
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Assumption of Liabilities--§ 357 |
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14 | (3) |
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Concept Summary: Tax Consequences of Liability Assumption |
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17 | (1) |
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Capital Structure Of A Corporation |
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18 | (1) |
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18 | (1) |
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Debt in the Capital Structure |
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18 | (3) |
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21 | (1) |
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Stock and Security Losses |
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21 | (1) |
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Business versus Nonbusiness Bad Debts |
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21 | (1) |
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Ethics & Equity: Can a Loss Produce a Double Benefit? |
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21 | (2) |
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23 | (1) |
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Gain From Qualified Small Business Stock |
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24 | (1) |
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24 | (1) |
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24 | (2) |
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Selecting Assets to Transfer |
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26 | (1) |
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Debt in the Capital Structure |
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26 | (1) |
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27 | (1) |
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Corporations versus Flow-Through Entities |
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28 | (1) |
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Refocus on the Big Picture: The Vehicle for Business Growth Is the Corporate Form |
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29 | |
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Chapter 5 Corporations: Earnings & Profits And Dividend Distributions |
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1 | (1) |
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The Big Picture: Taxing Corporate Distributions |
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1 | (1) |
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Corporate Distributions--Overview |
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2 | (1) |
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Earnings And Profits (E&P)--§ 312 |
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3 | (1) |
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3 | (3) |
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Summary of E & P Adjustments |
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6 | (1) |
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Concept Summary: E & P Adjustments |
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7 | (1) |
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Current versus Accumulated E & P |
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8 | (1) |
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Allocating E & P to Distributions |
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8 | (1) |
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Concept Summary: Allocating E & P to Distributions |
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9 | (3) |
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Ethics & Equity: Shifting E&P |
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12 | (1) |
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12 | (1) |
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Rationale for Reduced Tax Rates on Dividends |
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12 | (1) |
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13 | (1) |
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14 | (2) |
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Concept Summary: Noncash Property Distributions |
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16 | (1) |
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16 | (3) |
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Stock Dividends and Stock Rights |
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19 | (2) |
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21 | (1) |
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21 | (2) |
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Planning for Qualified Dividends |
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23 | (1) |
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24 | (2) |
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Refocus on the Big Picture: Taxing Corporate Distributions |
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26 | |
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Chapter 6 Corporations: Redemptions And Liquidations |
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1 | (1) |
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The Big Picture: Family Corporations and Stock Redemptions |
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1 | (1) |
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Stock Redemptions--In General |
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2 | (1) |
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Stock Redemptions--Sale Or Exchange Treatment |
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3 | (1) |
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Global Tax Issues: Foreign Shareholders Prefer Sale or Exchange Treatment in Stock Redemptions |
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4 | (1) |
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Historical Background and Overview |
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4 | (1) |
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Concept Summary: Summary of the Qualifying Stock Redemption Rules |
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5 | (1) |
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5 | (2) |
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Concept Summary: Tax Consequences of Stock Redemptions to Shareholders |
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7 | (1) |
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Not Essentially Equivalent Redemptions |
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7 | (1) |
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Disproportionate Redemptions |
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8 | (1) |
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Complete Termination Redemptions |
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9 | (1) |
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9 | (2) |
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Redemptions to Pay Death Taxes |
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11 | (1) |
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Stock Redemptions--Effect On The Corporation |
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11 | (1) |
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Recognition of Gain or Loss |
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12 | (1) |
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Effect on Earnings and Profits |
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12 | (1) |
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12 | (1) |
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Stock Redemptions--Preferred Stock Bailouts |
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12 | (1) |
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13 | (1) |
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13 | (1) |
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13 | (1) |
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14 | (1) |
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14 | (1) |
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Liquidating and Nonliquidating Distributions Compared |
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14 | (1) |
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Liquidations--Effect On The Distributing Corporation |
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15 | (1) |
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15 | (1) |
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16 | (3) |
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Concept Summary: Summary of Antistuffing Loss Disallowance Rules |
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19 | (1) |
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Liquidations--Effect On The Shareholder |
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20 | (1) |
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Ethics & Equity: Transferee Liability for Tax Deficiency of Liquidated Corporation |
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20 | (1) |
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Liquidations--Parent-Subsidiary Situations |
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21 | (1) |
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Minority Shareholder Interests |
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21 | (1) |
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Global Tax Issues: Basis Rules for Liquidations of Foreign Subsidiaries |
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21 | (1) |
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Indebtedness of the Subsidiary to the Parent |
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22 | (1) |
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Basis of Property Received by the Parent Corporation--The General Rule |
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22 | (1) |
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Basis of Property Received by the Parent Corporation--§ 338 Election |
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23 | (1) |
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Concept Summary: Summary of Liquidation Rules |
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23 | (2) |
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25 | (1) |
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25 | (1) |
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26 | (1) |
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Parent-Subsidiary Liquidations |
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27 | (1) |
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Asset Purchase versus Stock Purchase |
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27 | (1) |
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Refocus on the Big Picture: A Family Attribution Waiver Is a Valuable Tool in Succession Planning |
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28 | |
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Chapter 7 Corporations: Reorganizations |
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1 | (1) |
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The Big Picture: Structuring Acquisitions |
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1 | (1) |
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Corporate Reorganizations |
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2 | (1) |
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Different Types of Reorganizations |
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2 | (1) |
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Tax Consequences in a Tax-Free Reorganization |
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3 | (1) |
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Concept Summary: Gain and Basis Rules for Nontaxable Exchanges |
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3 | (2) |
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Concept Summary: Basis to Acquiring Corporation of Property Received |
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5 | (1) |
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Types Of Tax-Free Reorganizations |
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6 | (1) |
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6 | (2) |
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8 | (2) |
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10 | (2) |
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12 | (3) |
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15 | (1) |
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Concept Summary: Summary of Type A Through Type D Reorganizations: Advantages and Disadvantages |
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16 | (1) |
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17 | (1) |
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17 | (1) |
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18 | (1) |
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18 | (1) |
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18 | (1) |
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Continuity of Business Enterprise |
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19 | (1) |
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Continuity of Business Enterprise |
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19 | (1) |
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19 | (1) |
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Ethics & Equity: Poison Pills |
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19 | (1) |
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19 | (1) |
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Financial Disclosure Insights: Acquisitions Can Have Negative Consequences |
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20 | (1) |
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20 | (1) |
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Net Operating Loss Carryovers |
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20 | (2) |
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22 | (1) |
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Concept Summary: Treatment of E&P Carried to Successor |
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23 | (1) |
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23 | (1) |
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Concept Summary: Summary of Carryover Rules |
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24 | (1) |
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24 | (1) |
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Concept Summary: Comprehensive Summary of Corporate Reorganizations |
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25 | (1) |
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25 | (1) |
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Assessing Restructuring Options |
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25 | (2) |
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Refocus on the Big Picture: Structuring Acquisitions |
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27 | |
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Chapter 8 Consolidated Tax Returns |
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1 | (1) |
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The Big Picture: A Corporation Contemplates a Merger |
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1 | (1) |
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The Consolidated Return Rules |
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2 | (1) |
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Motivations to Consolidate |
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2 | (1) |
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Source and Philosophy of Consolidated Return Rules |
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3 | (1) |
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Ethics & Equity: Delegating Authority to the Nonelected |
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4 | (1) |
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Assessing Consolidated Return Status |
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4 | (1) |
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Financial Disclosure Insights: GAAP and Tax Treatment of Consolidations |
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5 | (1) |
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Electing Consolidated Return Status |
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6 | (1) |
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Concept Summary: The Consolidated Return Election |
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6 | (1) |
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7 | (1) |
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Affiliated versus Controlled Group |
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7 | (2) |
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Eligibility for the Consolidation Election |
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9 | (1) |
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10 | (4) |
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14 | (1) |
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Concept Summary: The Consolidated Tax Return |
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14 | (1) |
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Stock Basis Of Subsidiary |
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14 | (1) |
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Consolidated Taxable Income |
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15 | (1) |
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16 | (1) |
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Typical Intercompany Transactions |
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17 | (2) |
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Global Tax Issues: Consolidated Returns and NOLs |
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19 | (4) |
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23 | (2) |
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25 | (1) |
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Concept Summary: Consolidated Taxable Income |
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26 | (1) |
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27 | (1) |
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Choosing Consolidated Return Partners |
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27 | (1) |
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Consolidation versus 100 Percent Dividends Received Deduction |
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27 | (1) |
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Protecting the Group Members' Liability for Tax Payments |
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27 | (1) |
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27 | (1) |
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Refocus on the Big Picture: Should the Affiliated Group File a Consolidated Return? |
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28 | |
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Chapter 9 Taxation Of International Transactions |
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1 | (1) |
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The Big Picture: Going International |
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1 | (2) |
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Overview Of International Taxation |
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3 | (2) |
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5 | (1) |
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Global Tax Issues: CO WD-19 and Permanent Establishment |
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6 | (1) |
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Sourcing Of Income And Deductions |
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6 | (1) |
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7 | (2) |
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Allocation and Apportionment of Deductions |
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9 | (1) |
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Concept Summary: The Sourcing Rules |
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10 | (1) |
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10 | (1) |
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Ethics & Equity: The Costs of Good Tax Planning |
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11 | (3) |
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Foreign Currency Gain/Loss |
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14 | (1) |
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U.S. Persons With Offshore Income |
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15 | (1) |
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Export Property, Licenses, Foreign Branches |
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15 | (2) |
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Financial Disclosure Insights: Overseas Operations and Book-Tax Differences |
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17 | (1) |
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Concept Summary: The Foreign Tax Credit |
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17 | (1) |
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18 | (1) |
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Offshore (Foreign) Corporations Controlled by U.S. Persons |
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19 | (2) |
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Concept Summary: Subpart F Income and a CFC |
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21 | (2) |
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Concept Summary: Components of Subpart F Income |
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23 | (1) |
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Movement Toward a More Territorial System |
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23 | (2) |
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U.S. Taxation Of Nonresident Aliens And Foreign Corporations |
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25 | (1) |
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Nonresident Alien Individuals |
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25 | (2) |
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27 | (1) |
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Foreign Investment in Real Property Tax Act |
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28 | (1) |
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Expatriation to Avoid U.S. Taxation |
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28 | (1) |
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29 | (1) |
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29 | (1) |
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The Foreign Tax Credit Limitation and Sourcing Provisions |
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29 | (1) |
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30 | (1) |
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Refocus on the Big Picture: Going International |
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31 | |
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Part 3 Flow-Through Entities |
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Chapter 10 Partnerships: Formation, Operation, And Basis |
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1 | (1) |
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The Big Picture: Why Use a Partnership, Anyway? |
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1 | (1) |
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Overview Of Partnership Taxation |
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2 | (1) |
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2 | (2) |
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Concept Summary: Comparison of Partnership Types |
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4 | (1) |
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Key Concepts in Taxation of Partnership Income |
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4 | (2) |
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Formation Of A Partnership: Tax Effects |
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6 | (1) |
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Contributions to the Partnership |
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6 | (1) |
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Exceptions to the General Rule of § 721 |
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7 | (2) |
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Other Issues Related to Contributed Property |
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9 | (2) |
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Concept Summary: Partnership Formation and Initial Basis Computation |
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11 | (1) |
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11 | (1) |
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Initial Costs of a Partnership |
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12 | (1) |
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12 | (1) |
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Taxable Year of the Partnership |
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13 | (1) |
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Partnership Operations And Reporting |
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14 | (1) |
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Partnership Reporting, In General |
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14 | (1) |
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Measuring Partnership Income |
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15 | (3) |
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18 | (5) |
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Financial Disclosure Insights: Financial Reporting for Partnerships |
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23 | (1) |
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Partner Calculations And Reporting |
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24 | (1) |
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Partner Reporting of Partnership Income |
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24 | (2) |
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26 | (2) |
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28 | (2) |
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Concept Summary: Tax Reporting of Partnership Items |
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30 | (1) |
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Ethics & Equity: Built-in Appreciation on Contributed Property |
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30 | (1) |
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31 | (1) |
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Effect of Partnership Liabilities on Partner's Basis |
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32 | (3) |
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Partner's Capital Account |
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|
35 | (1) |
|
Concept Summary: Comparing a Partner's Tax Basis and Capital Account |
|
|
36 | (1) |
|
|
36 | (2) |
|
Othertaxes On Partnership Income |
|
|
38 | (1) |
|
Global Tax Issues: Withholding Requirements fornon-U.S. Partners |
|
|
38 | (1) |
|
|
39 | (1) |
|
Net Investment Income Tax |
|
|
39 | (1) |
|
|
40 | (1) |
|
Choosing Partnership Taxation |
|
|
40 | (1) |
|
Formation and Operation of a Partnership |
|
|
41 | (1) |
|
Basis Considerations and Loss Deduction Limitations |
|
|
41 | (1) |
|
Concept Summary: Major Advantages and Disadvantages of the Partnership Form |
|
|
41 | (1) |
|
Partnership Reporting Requirements |
|
|
42 | (1) |
|
Transactions between Partners and Partnerships |
|
|
42 | (1) |
|
Drafting the Partnership Agreement |
|
|
42 | (1) |
|
Refocus on the Big Picture: Why Use a Partnership, Anyway? |
|
|
43 | |
|
Chapter 11 Partnerships: Distributions, Transfer Of Interests, And Terminations |
|
|
1 | (1) |
|
The Big Picture: The Life Cycle of a Partnership |
|
|
1 | (1) |
|
Distributions From A Partnership |
|
|
2 | (1) |
|
|
2 | (2) |
|
Concept Summary: Hot Assets |
|
|
4 | (1) |
|
Proportionate Current Distributions |
|
|
4 | (3) |
|
Ethics & Equity: Arranging Tax-Advantaged Distributions |
|
|
7 | (1) |
|
Concept Summary: Proportionate Current Distributions (General Rules) |
|
|
8 | (1) |
|
Proportionate Liquidating Distributions |
|
|
8 | (3) |
|
Property Distributions with Special Tax Treatment |
|
|
11 | (1) |
|
Concept Summary: Proportionate Liquidating Distributions When the Partnership Also Liquidates (General Rules) |
|
|
12 | (1) |
|
Disproportionate Distributions |
|
|
13 | (1) |
|
Section 736--Liquidating Distributions To Retiring Or Deceased Partners |
|
|
14 | (1) |
|
General Partners in Service-Providing Partnerships |
|
|
14 | (2) |
|
Limited Partners or Capital-intensive Partnerships |
|
|
16 | (1) |
|
Tax Treatment of § 736 Payments |
|
|
16 | (3) |
|
Concept Summary: Liquidating Distributions of Cash When the Partnership Continues |
|
|
19 | (1) |
|
Sale Of A Partnership Interest |
|
|
19 | (1) |
|
|
19 | (2) |
|
Hot Assets and Carried Interests |
|
|
21 | (2) |
|
Concept Summary: Sale of a Partnership Interest |
|
|
23 | (1) |
|
Global Tax Issues: A Partnership Isn't Always a Partnership--Complications in the Global Arena |
|
|
23 | (1) |
|
Other Dispositions Of Partnership Interests |
|
|
24 | (1) |
|
Transfers to a Corporation |
|
|
24 | (1) |
|
|
24 | (1) |
|
|
24 | (1) |
|
Section 754--Optional Adjustments To Property Basis |
|
|
25 | (1) |
|
Adjustment: Sale or Exchange of an Interest |
|
|
26 | (1) |
|
Adjustment: Partnership Distributions |
|
|
27 | (2) |
|
Concept Summary: Basis Adjustments under § 754 |
|
|
29 | (1) |
|
|
29 | (1) |
|
Termination of a Partnership |
|
|
29 | (1) |
|
|
30 | (1) |
|
Global Tax Issues: Sale of Global Partnership Interests |
|
|
31 | (1) |
|
Limited Liability Companies |
|
|
31 | (1) |
|
Limited Liability Partnerships |
|
|
32 | (1) |
|
Partnership Administration and Anti-Abuse |
|
|
32 | (1) |
|
|
32 | (1) |
|
Planning Partnership Distributions |
|
|
32 | (1) |
|
Sales and Exchanges of Partnership Interests |
|
|
33 | (1) |
|
Comparing Sales to Liquidations |
|
|
33 | (2) |
|
Other Partnership Issues 11-34 Refocus on the Big Picture: The Life Cycle of a Partnership |
|
|
35 | |
|
Chapter 12 S Corporations |
|
|
1 | (1) |
|
The Big Picture: Deductibility of Losses and the Choice of Business Entity |
|
|
1 | (1) |
|
Choice Of Business Entity |
|
|
2 | (1) |
|
An Overview of S Corporations |
|
|
2 | (1) |
|
Qualifying For S Corporation Status |
|
|
3 | (1) |
|
Defining an S Corporation |
|
|
3 | (2) |
|
|
5 | (1) |
|
|
6 | (1) |
|
|
7 | (2) |
|
|
9 | (1) |
|
|
9 | (3) |
|
Qualified Business Income Deduction |
|
|
12 | (1) |
|
Allocation of Income and Loss |
|
|
12 | (1) |
|
Distributions to Shareholders |
|
|
13 | (1) |
|
Concept Summary: Classification Procedures for Distributions from an S Corporation |
|
|
14 | (4) |
|
Noncash Property Distributions |
|
|
18 | (1) |
|
Concept Summary: Consequences of Noncash Distributions |
|
|
18 | (1) |
|
Shareholder's Basis in S Stock |
|
|
19 | (2) |
|
|
21 | (1) |
|
Tax on Pre-Election Built-in Gain |
|
|
22 | (1) |
|
|
23 | (1) |
|
Passive Investment Income Penalty Tax |
|
|
23 | (1) |
|
|
24 | (1) |
|
|
25 | (1) |
|
When the Election Is Advisable |
|
|
25 | (1) |
|
Concept Summary: Making an S Election |
|
|
25 | (1) |
|
|
26 | (1) |
|
Operation of the S Corporation |
|
|
26 | (1) |
|
Refocus on the Big Picture: Using a Pass-Through Entity to Achieve Deductibility of Losses |
|
|
27 | |
|
Part 4 Advanced Tax Practice Considerations |
|
|
|
Chapter 13 Comparative Forms Of Doing Business |
|
|
1 | (1) |
|
The Big Picture: Selection of a Tax Entity Form |
|
|
1 | (1) |
|
|
2 | (1) |
|
|
3 | (1) |
|
|
3 | (1) |
|
|
4 | (1) |
|
|
4 | (1) |
|
Single Versus Double Taxation |
|
|
4 | (1) |
|
Overall Effect on Entity and Owners |
|
|
4 | (2) |
|
|
6 | (1) |
|
|
6 | (1) |
|
Global Tax Issues: Tax Rates and Economic Activity |
|
|
7 | (1) |
|
Controlling The Entity Tax |
|
|
7 | (1) |
|
Favorable Treatment of Certain Fringe Benefits |
|
|
8 | (1) |
|
Minimizing Double Taxation |
|
|
8 | (3) |
|
Considering the Qualified Business Income Deduction |
|
|
11 | (1) |
|
Conduit Versus Entity Treatment |
|
|
11 | (1) |
|
Effect on Recognition at Time of Contribution to the Entity |
|
|
11 | (1) |
|
Effect on Basis of Ownership Interest |
|
|
12 | (1) |
|
Ethics & Equity: Income Tax Basis That Does Not Change? |
|
|
13 | (1) |
|
Effect on Results of Operations |
|
|
13 | (1) |
|
Effect on Recognition at Time of Distribution |
|
|
14 | (1) |
|
Effect on Passive Activity Losses |
|
|
15 | (1) |
|
|
15 | (1) |
|
Effect of Special Allocations |
|
|
16 | (1) |
|
FICA, Self-Employment Taxes, And Nut |
|
|
17 | (1) |
|
|
17 | (1) |
|
|
17 | (1) |
|
Net Investment Income Tax (NUT) |
|
|
18 | (1) |
|
Effect on the Entity and Its Owners |
|
|
18 | (1) |
|
Disposition Of A Business Or An Ownership Interest |
|
|
19 | (1) |
|
|
19 | (1) |
|
Partnership and Limited Liability Company |
|
|
20 | (1) |
|
|
21 | (1) |
|
|
22 | (1) |
|
Converting To Other Entity Types |
|
|
23 | (1) |
|
|
23 | (1) |
|
|
23 | (1) |
|
|
23 | (1) |
|
Overall Comparison Of Forms Of Doing Business |
|
|
24 | (1) |
|
Concept Summary: Tax Attributes of Different Forms of Business (Assume That Partners and Shareholders Are All Individuals) |
|
|
24 | (4) |
|
|
28 | (1) |
|
Refocus on the Big Picture: Selection of a Tax Entity Form |
|
|
29 | |
|
Chapter 14 Taxes In The Financial Statements |
|
|
1 | (1) |
|
The Big Picture: Taxes in the Financial Statements |
|
|
1 | (1) |
|
Accounting For Income Taxes--Basic Principles |
|
|
2 | (1) |
|
|
2 | (3) |
|
Concept Summary: Common Book-Tax Differences |
|
|
5 | (1) |
|
Generally Accepted Accounting Principles and ASC 740 |
|
|
5 | (2) |
|
Capturing, Measuring, And Recording Tax Expense--The Provision Process |
|
|
7 | (1) |
|
|
8 | (1) |
|
Global Tax Issues: Accounting for Income Taxes under International Standards |
|
|
9 | (1) |
|
|
9 | (1) |
|
Financial Disclosure Insights: The Book-Tax Income Gap |
|
|
9 | (5) |
|
|
14 | (1) |
|
Global Tax Issues: Tax Losses and the Deferred Tax Asset |
|
|
15 | (2) |
|
Tax Disclosures In The Financial Statements |
|
|
17 | (1) |
|
Presentation of Amounts Recognized in the Financial Statements |
|
|
17 | (1) |
|
The Financial Statement Footnotes |
|
|
18 | (1) |
|
The Effective Tax Rate Reconciliation |
|
|
18 | (2) |
|
|
20 | (1) |
|
The Financial Accounting for Tax Uncertainties |
|
|
20 | (1) |
|
Concept Summary: Recognizing the Tax Benefits of Uncertain Tax Positions Under ASC 740-10 |
|
|
21 | (3) |
|
Ethics & Equity: Disclosing Aggressive Tax Positions |
|
|
24 | (1) |
|
Effects of Statutory Tax Rate Cha nges |
|
|
24 | (1) |
|
Repeal of the Corporate Alternative MinimumTax |
|
|
25 | (1) |
|
The Corporate Tax Department |
|
|
25 | (1) |
|
Concept Summary: The Income Tax Provision Process |
|
|
26 | (1) |
|
|
26 | (1) |
|
|
27 | (1) |
|
|
28 | (1) |
|
Uses of Benchmarking Analysis |
|
|
28 | (1) |
|
Concept Summary: Benchmarking Analysis |
|
|
29 | (1) |
|
|
29 | (1) |
|
Releasing Valuation Allowances |
|
|
29 | (1) |
|
|
30 | (1) |
|
Refocus on the Big Picture: Taxes in the Financial Statements |
|
|
31 | |
|
Chapter 15 Exempt Entities |
|
|
1 | (1) |
|
The Big Picture: Effect of a For-Profit Business on a Tax-Exempt Entity |
|
|
1 | (2) |
|
Types Of Exempt Organizations |
|
|
3 | (1) |
|
Characteristics Of Exempt Entities |
|
|
3 | (1) |
|
|
3 | (1) |
|
|
3 | (1) |
|
|
3 | (2) |
|
Concept Summary: Consequences of Exempt Status |
|
|
5 | (1) |
|
|
5 | (1) |
|
|
5 | (3) |
|
|
8 | (1) |
|
|
8 | (1) |
|
Tax Consequences of Private Foundation Status |
|
|
8 | (2) |
|
Concept Summary: Exempt Organizations: Classification |
|
|
10 | (1) |
|
Taxes Imposed on Private Foundations |
|
|
11 | (1) |
|
Unrelated Business Income Tax |
|
|
12 | (1) |
|
Unrelated Trade or Business |
|
|
13 | (3) |
|
Unrelated Business Taxable Income |
|
|
16 | (2) |
|
Concept Summary: Unrelated Business Income Tax |
|
|
18 | (1) |
|
|
19 | (1) |
|
Obtaining Exempt Organization Status |
|
|
19 | (1) |
|
Annual Filing Requirements |
|
|
19 | (1) |
|
|
20 | (1) |
|
|
21 | (1) |
|
Choosing an Exempt Classification |
|
|
21 | (1) |
|
Maintaining Exempt Status |
|
|
21 | (1) |
|
|
22 | (1) |
|
Unrelated Business Income Tax |
|
|
22 | (1) |
|
Refocus on the Big Picture: Effect of a For-Profit Business on a Tax-Exempt Entity |
|
|
23 | |
|
Chapter 16 Multistate Corporate Taxation |
|
|
1 | (1) |
|
The Big Picture: Making a Multistate Location Decision |
|
|
1 | (1) |
|
Corporate State Income Taxation |
|
|
2 | (1) |
|
Computing State Income Tax |
|
|
2 | (1) |
|
|
3 | (1) |
|
The UDITPA and the Multistate Tax Commission |
|
|
3 | (3) |
|
Jurisdiction to Impose Tax: Nexus and Public Law 86-272 |
|
|
6 | (1) |
|
|
7 | (1) |
|
Concept Summary: Multistate Taxation |
|
|
8 | (1) |
|
Apportionment And Allocation Of Income |
|
|
8 | (1) |
|
The Apportionment Procedure |
|
|
9 | (1) |
|
|
9 | (2) |
|
Apportionment Factors: Elements and Planning |
|
|
11 | (1) |
|
Concept Summary: Apportionable Income |
|
|
12 | (1) |
|
|
13 | (1) |
|
|
14 | (2) |
|
|
16 | (1) |
|
Financial Disclosure Insights: State/Local Taxes and the Tax Expense |
|
|
17 | (1) |
|
|
18 | (1) |
|
What Is a Unitary Business? |
|
|
19 | (1) |
|
Tax Effects of the Unitary Theory |
|
|
19 | (2) |
|
Consolidated and Combined Returns |
|
|
21 | (1) |
|
Global Tax Issues: Water's Edge Is Not a Day at the Beach |
|
|
21 | (1) |
|
Concept Summary: Using Apportionment Formulas |
|
|
22 | (1) |
|
Taxation Of S Corporations |
|
|
22 | (1) |
|
|
22 | (1) |
|
State Tax Filing Requirements |
|
|
22 | (1) |
|
Taxation Of Partnerships And LLCS |
|
|
23 | (1) |
|
Other State And Local Taxes |
|
|
23 | (1) |
|
State and Local Sales and Use Taxes |
|
|
23 | (2) |
|
|
25 | (1) |
|
|
26 | (1) |
|
Ethics & Equity: Encouraging Economic Development through Tax Concessions |
|
|
27 | (1) |
|
|
28 | (1) |
|
Selecting the Optimal State in Which to Operate |
|
|
28 | (1) |
|
Restructuring Corporate Entities |
|
|
29 | (2) |
|
Subjecting the Corporation's Income to Apportionment |
|
|
31 | (1) |
|
Ethics & Equity: Can You Be a Nowhere Adviser? |
|
|
32 | (1) |
|
Planning with Apportionment Factors |
|
|
32 | (1) |
|
|
33 | (1) |
|
|
33 | (1) |
|
Refocus on the Big Picture: Making a Multistate Location Decision |
|
|
33 | |
|
Chapter 17 Tax Practice And Ethics |
|
|
1 | (1) |
|
The Big Picture: A Tax Adviser's Dilemma |
|
|
1 | (1) |
|
|
2 | (1) |
|
Organizational Structure of the IRS |
|
|
3 | (1) |
|
IRS Procedure--Letter Rulings |
|
|
4 | (1) |
|
IRS Procedure--Other Issuances |
|
|
4 | (1) |
|
Ethics & Equity: Tax Compliance Costs |
|
|
5 | (1) |
|
Administrative Powers of the IRS |
|
|
5 | (1) |
|
|
6 | (1) |
|
Ethics & Equity: Can the IRS Pretend to Be Your Friend? |
|
|
7 | (2) |
|
The Taxpayer Appeal Process |
|
|
9 | (1) |
|
Offers in Compromise and Closing Agreements |
|
|
10 | (1) |
|
Ethics & Equity: Our Taxing System of Self-Assessment |
|
|
11 | (1) |
|
|
12 | (1) |
|
Concept Summary: Working with the IRS |
|
|
13 | (1) |
|
|
13 | (5) |
|
Ethics & Equity: First-Time Tax Violators Can Get Off with Just a Warning |
|
|
18 | (3) |
|
|
21 | (1) |
|
The Tax Profession And Tax Ethics |
|
|
22 | (1) |
|
|
22 | (1) |
|
|
23 | (1) |
|
IRS Rules Governing Tax Practice |
|
|
23 | (1) |
|
|
24 | (2) |
|
Privileged Communications |
|
|
26 | (1) |
|
AICPA Statements on Standards for Tax Services |
|
|
27 | (3) |
|
Concept Summary: Tax Profession and Ethics |
|
|
30 | (1) |
|
|
30 | (1) |
|
Strategies in Seeking a Letter Ruling |
|
|
30 | (1) |
|
Considerations in Handling an IRS Audit |
|
|
30 | (1) |
|
|
31 | (1) |
|
Litigation Considerations |
|
|
32 | (1) |
|
|
32 | (1) |
|
Ethics in the Tax Practice |
|
|
32 | (1) |
|
Privileged Communications |
|
|
33 | (1) |
|
Refocus on the Big Picture: A Tax Adviser's Dilemma |
|
|
33 | |
|
Part 5 Family Tax Planning |
|
|
|
Chapter 18 The Federal Gift And Estate Taxes |
|
|
1 | (1) |
|
The Big Picture: An Eventful and Final Year |
|
|
1 | (1) |
|
Transfer Taxes--In General |
|
|
2 | (1) |
|
|
2 | (1) |
|
Global Tax Issues: U.S. Transfer Taxes and NRAs |
|
|
3 | (1) |
|
Concept Summary: Formula for the Federal Gift Tax |
|
|
4 | (1) |
|
Concept Summary: Formula for the Federal Estate Tax |
|
|
4 | (1) |
|
|
5 | (1) |
|
|
6 | (1) |
|
|
7 | (1) |
|
|
7 | (1) |
|
Ethics & Equity: It's the Thought That Counts |
|
|
7 | (2) |
|
Transfers Subject to the Gift Tax |
|
|
9 | (1) |
|
Annual Gift Tax Exclusion |
|
|
10 | (1) |
|
|
11 | (1) |
|
Computing the Federal Gift Tax |
|
|
11 | (1) |
|
|
12 | (1) |
|
Concept Summary: Federal Gift Tax Provisions |
|
|
13 | (1) |
|
|
13 | (1) |
|
|
14 | (5) |
|
Concept Summary: Federal Estate Tax Provisions--Gross Estate |
|
|
19 | (1) |
|
|
19 | (4) |
|
|
23 | (1) |
|
Global Tax Issues: Treaty Relief Is Not Abundant! |
|
|
24 | (1) |
|
|
25 | (1) |
|
Concept Summary: Federal Estate Tax Provisions--Taxable Estate and Procedural Matters |
|
|
25 | (1) |
|
The Generation-Skipping Transfer Tax |
|
|
25 | (1) |
|
Inter-Generational Transfers |
|
|
25 | (1) |
|
The Tax on Generation-Skipping Transfers |
|
|
26 | (1) |
|
|
26 | (1) |
|
Refocus on the Big Picture: An Eventful and Final Year |
|
|
27 | |
|
Chapter 19 Family Tax Planning |
|
|
1 | (1) |
|
The Big Picture: Lifetime Giving--the Good and the Bad |
|
|
1 | (1) |
|
|
2 | (1) |
|
|
2 | (1) |
|
Valuation of Specific Assets |
|
|
3 | (1) |
|
Ethics & Equity: One Way to Handle Loans to Troublesome In-Laws |
|
|
4 | (1) |
|
Ethics & Equity: Can IRS Valuation Tables Be Disregarded? |
|
|
5 | (1) |
|
Real Estate and the Special Use Valuation Method |
|
|
5 | (1) |
|
Valuation Problems with a Closely Held Business |
|
|
6 | (4) |
|
Concept Summary: Valuation of Transferred Assets |
|
|
10 | (1) |
|
|
10 | (1) |
|
Basis of Property Acquired by Gift |
|
|
10 | (1) |
|
Basis of Property Acquired by Death |
|
|
11 | (2) |
|
Concept Summary: Income Tax Basis of Transferred Assets |
|
|
13 | (1) |
|
|
13 | (1) |
|
|
14 | (1) |
|
|
14 | (1) |
|
Income Tax Considerations |
|
|
15 | (2) |
|
|
17 | (1) |
|
|
17 | (1) |
|
|
17 | (3) |
|
Providing Estate Liquidity |
|
|
20 | (2) |
|
Nontax Estate Planning Issues |
|
|
22 | (1) |
|
Concept Summary: Estate and Gift Tax Planning |
|
|
22 | (1) |
|
Refocus on the Big Picture: Lifetime Giving--the Good and the Bad |
|
|
23 | |
|
Chapter 20 Income Taxation Of Trusts And Estates |
|
|
1 | (1) |
|
The Big Picture: Setting Up a Trust to Protect a Family |
|
|
1 | (1) |
|
Fiduciary Income Taxation |
|
|
2 | (1) |
|
|
2 | (3) |
|
|
5 | (1) |
|
Nature Of Trust And Estate Taxation |
|
|
5 | (1) |
|
Concept Summary: Tax Characteristics of Major Pass-Through Entities |
|
|
6 | (1) |
|
Tax Accounting Periods and Methods |
|
|
6 | (1) |
|
Tax Rates and Personal Exemption |
|
|
6 | (1) |
|
|
7 | (1) |
|
Additional Tax on Net Investment Income |
|
|
8 | (1) |
|
Taxable Income Of Trusts And Estates |
|
|
8 | (1) |
|
|
8 | (3) |
|
|
11 | (2) |
|
Ethics & Equity: To Whom Can I Trust My Pet? |
|
|
13 | (1) |
|
|
13 | (2) |
|
|
15 | (1) |
|
|
15 | (1) |
|
Deduction for Distributions to Beneficiaries |
|
|
16 | (1) |
|
Concept Summary: Uses of the DNI Amount |
|
|
17 | (2) |
|
|
19 | (1) |
|
Concept Summary: Principles of Fiduciary Income Taxation |
|
|
20 | (1) |
|
Taxation Of Beneficiaries |
|
|
20 | (1) |
|
Distributions by Simple Trusts |
|
|
20 | (1) |
|
Distributions by Estates and Complex Trusts |
|
|
20 | (2) |
|
|
22 | (1) |
|
|
23 | (2) |
|
|
25 | (1) |
|
|
25 | (1) |
|
A Trust or an Estate as an Income-Shifting Device |
|
|
25 | (1) |
|
Income Tax Planning for Estates |
|
|
26 | (1) |
|
Distributions of In-Kind Property |
|
|
27 | (1) |
|
Ethics & Equity: Who Should Be a Trustee? |
|
|
27 | (1) |
|
Deductibility of Administrative Expenses |
|
|
27 | (1) |
|
|
28 | (1) |
|
Additional Taxes on Capital Gains and Net Investment Income |
|
|
28 | (1) |
|
Refocus on the Big Picture: Setting Up a Trust to Protect a Family |
|
|
29 | |
|
|
|
Tax Formulas, Tax Rate Schedules, And Tables |
|
|
1 | (1) |
|
|
1 | (1) |
|
|
1 | (1) |
|
Table Of Code Sections Cited |
|
|
1 | (1) |
|
Present Value And Future Value Tables |
|
|
1 | (1) |
Index |
|
1 | |