Federal Income Taxation of Corporations, Second Edition / Edition 2

Federal Income Taxation of Corporations, Second Edition / Edition 2

by Donald L. Doernberg, Howard E. Abrams
     
 

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

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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:
06/28/1994
Series:
Law School Casebook Series
Edition description:
Older Edition
Pages:
1208

Table of Contents

Preface
1Introduction to the Corporate Income Tax1
IFormation and Operation of a Corporation5
2Corporate Formation7
3Corporate Operation81
IICorporate Distributions: Nonliquidating and Liquidating117
4Distributions of Cash and Property119
5Redemptions and Partial Liquidations185
6Distributions of Stock279
7Liquidations327
8Integration of the Corporate and Individual Income Taxes361
IIIAcquisition of a Corporate Business: Taxable and Tax Free377
9Taxable Acquisitions379
10Acquisitive Reorganizations411
11Divisive Reorganizations501
12One-Party Reorganizations539
13Combining Tax Attributes: Net Operating Losses and Affiliated Corporations549
IVMiscellaneous Corporate Tax Topics581
14Penalty Provisions583
15The Corporation as a Separate Taxable Entity633
16S Corporations and Their Shareholders683
Table of Cases729
Table of Revenue Rulings and Procedures735
Index737

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