(NOTE: All chapters include sections on Tax Planning Considerations and Compliance and Procedural Considerations, except 1 and 16 . All chapters also include Problem Materials.)
1. Tax Research.
Overview of Tax Research. Steps in the Tax Research Process. Importance of the Facts to the Tax Results. The Sources of Tax Law. Tax Services. Citators. Computers as a Research Tool. Statements on Responsibilities in Tax Practice. Sample Work Papers and Client Letter.
2. Corporate Formations and Capital Structure.
Organization Forms Available. Definition of a Corporation. Legal Requirements for Forming a Corporation. Tax Considerations in Forming a Corporation. Section 351: Deferring Gain or Loss Upon Incorporation. Choice of Capital Structure. Worthlessness of Stock or Debt Obligations.
3. The Corporate Income Tax.
Corporate Elections. General Formula for Determining the Corporate Tax Liability. Computing a Corporation's Taxable Income. Computing a Corporation's Income Tax Liability. Controlled Groups of Corporations. Compensation Planning for Shareholder-Employees.
4. Corporate Nonliquidating Distributions.
Distributions in General. Earnings and Profits (E&P). Property Distributions. Stock Dividends and Stock Rights. Stock Redemptions. Preferred Stock Bailouts. Stock Redemptions by Related Corporations.
5. Other Corporate Tax Levies.
The Corporate Alternative Minimum Tax. Superfund Environmental Tax. Personal Holding CompanyTax. Accumulated Earnings Tax. Unrelated Business Income Tax.
6. Corporate Liquidating Distributions.
Tax Consequences of Corporate Liquidations. Effects of Liquidating on the Shareholders. Effects of Liquidating on the Liquidating Corporation. Corporate Liquidations as Part of Taxable Asset Acquisitions.
7. Corporate Acquisitions and Reorganizations.
Characteristics of Taxable and Tax-Free Transactions. Types of Tax-Free Reorganizations. Tax Consequences of Reorganizations. Acquisitive Reorganizations. Divisive Reorganizations. Other Reorganization Transactions. Judicial Restrictions on the Use of Corporate Reorganizations. Tax Attributes.
8. Consolidated Tax Returns.
Source of the Consolidated Tax Return Rules. Definition of an Affiliated Group. Should a Consolidated Return be Filed? Consolidated Taxable Income. Intercompany Transactions. Dividends Received by Group Members. Consolidated Charitable Contributions Deduction. Net Operating Losses (NOLs). Consolidated Capital Gains and Losses. Computation of the Affiliated Group's Tax Liability. Consolidated Tax Credits, Stock Basis Adjustments.
9. Partnership Formation and Operation.
Definition of a Partnership. Overview of Partnership Taxation. Tax Implications of Formation of a Partnership. Partnership Elections. Partnership Reporting of Income. Partner Reporting of Income. Basis for Partnership Interest. Special Loss Limitations. Transactions Between a Partner and the Partnership. Family Partnerships.
10. Special Partnership Issues.
Nonliquidating Distributions. Nonliquidating Distributions with Sec. 751. Terminating an Interest in a Partnership. Optional Basis Adjustments. Special Forms of Partnerships.
11. S Corporations.
Should an S Corporation Election be Made? S Corporation Requirements. Election of S Corporation Status. S Corporation Operations. Taxation of the Shareholder. Basis Adjustments. S Corporation Distributions. Other Rules.
12. The Gift Tax.
Concept of Transfer Taxes. The Unified Transfer Tax System. Gift Tax Formula. Transfers Subject to the Gift Tax. Exclusions. Gift Tax Deductions. The Gift-Splitting Election. Computation of the Gift Tax Liability. Comprehensive Illustration. Basis Considerations for a Lifetime Giving Plan. Below Market Loans: Gift and Income Tax Consequences.
13. The Estate Tax.
Estate Tax Formula. The Gross Estate—Valuation. The Gross Estate—Inclusions. Deductions. Computation of Tax Liability. Comprehensive Illustration. Liquidity Concerns. Generation—Skipping Transfer Tax.
14. Income Taxation of Trusts and Estates.
Basic Concepts. Principles of Fiduciary Accounting. Formula for Taxable Income and Tax Liability. Distributable Net Income. Determining a Simple Trust's Taxable Income. Comprehensive Illustration—Determining a Simple Trust's Taxable Income. Determining Taxable Income for Complex Trusts and Estates. Comprehensive Illustration—Determining a Complex Trust's Taxable Income. Accumulation Distribution Rules. Section 644 Tax. Income in Respect of a Decedent. Grantor Trust Provisions.
15. Administrative Procedures.
Role of the Internal Revenue Service. Audits of Tax Returns. Requests for Rulings. Due Dates. Estimated Taxes. Other More Severe Penalties. Statute of Limitations. Liability for Tax. Tax Practice Issues.
16. U.S. Taxation of Foreign-Related Transactions.
Jurisdiction to Tax. Taxation of U.S. Citizens and Resident Aliens. Taxation of Nonresident Aliens. Taxation of U.S. Persons Doing Business Abroad.