Federal Income Taxation of Corporations, Second Edition / Edition 2

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Overview

Announcing the long-awaited revision of noted tax expert Bill Andrews; corporate tax casebook! New co-author Alan Feld joins Professor Andrews in meticulously updating FEDERAL INCOME TAXATION OF CORPORATE TRANSACTIONS to reflect the latest statutory changes through 1993, as well as new cases and developments in corporate tax. The Third Edition features: more international cases, such as Gulf Oil Corp. v. Commissioner, affording more opportunities to explore complex transactions numerous new cases selected for currency and pedagogy discussion of leveraged buyouts and related trends of the 1980s-put into perspective thorough treatment of the important new rate advantage for long term capital gains, especially with regard to discussion of redemption transactions This new edition maintains the overall organization of previous editions. The authors begin with a general introduction that deals with early stock dividend cases and the repeal of the General Utilities doctrine. They then consider reorganization and related non-recognized provisions-before examining distributions to shareholders and corporate taxable income. This very effective approach immerses students early in the interplay of complex transactions, statutes, and unpredictable interpretations; introduces court-made doctrines in their original setting; and gives students a realistic context for studying corporate tax concepts. For skillful analysis of corporate tax policy, adopt FEDERAL INCOME TAXATION OF CORPORATE TRANSACTIONS, Third Edition. Its insightful Teacher's Manual completes a truly outstanding teaching package.

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Product Details

  • ISBN-13: 9780316188388
  • Publisher: Wolters Kluwer Law & Business
  • Publication date: 6/28/1994
  • Series: Law School Casebook Series
  • Edition description: Older Edition
  • Edition number: 2
  • Pages: 1208

Table of Contents

Preface
1 Introduction to the Corporate Income Tax 1
I Formation and Operation of a Corporation 5
2 Corporate Formation 7
3 Corporate Operation 81
II Corporate Distributions: Nonliquidating and Liquidating 117
4 Distributions of Cash and Property 119
5 Redemptions and Partial Liquidations 185
6 Distributions of Stock 279
7 Liquidations 327
8 Integration of the Corporate and Individual Income Taxes 361
III Acquisition of a Corporate Business: Taxable and Tax Free 377
9 Taxable Acquisitions 379
10 Acquisitive Reorganizations 411
11 Divisive Reorganizations 501
12 One-Party Reorganizations 539
13 Combining Tax Attributes: Net Operating Losses and Affiliated Corporations 549
IV Miscellaneous Corporate Tax Topics 581
14 Penalty Provisions 583
15 The Corporation as a Separate Taxable Entity 633
16 S Corporations and Their Shareholders 683
Table of Cases 729
Table of Revenue Rulings and Procedures 735
Index 737
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