ISBN-10:
0130202835
ISBN-13:
9780130202833
Pub. Date:
04/28/1999
Publisher:
Prentice Hall Professional Technical Reference
Prentice Hall's Federal Taxation, 2000: Corporations, Partnerships, Estates and Trusts / Edition 1

Prentice Hall's Federal Taxation, 2000: Corporations, Partnerships, Estates and Trusts / Edition 1

by Thomas R. Pope, John L. Kramer

Hardcover

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Product Details

ISBN-13: 9780130202833
Publisher: Prentice Hall Professional Technical Reference
Publication date: 04/28/1999
Edition description: Older Edition
Pages: 928
Product dimensions: 8.79(w) x 11.16(h) x 1.32(d)

Table of Contents

Preface xi
Tax Research
1(1)
Overview of Tax Research
2(1)
Steps in the Tax Research Process
3(2)
Importance of the Facts to the Tax Consequences
5(1)
Ability to Design a Factual Situation Favoring the Taxpayer
6(1)
The Sources of Tax Law
6(18)
The Legislative Process
7(1)
The Internal Revenue Code
8(1)
Treasury Regulations
9(2)
Administrative Interpretations
11(3)
Judicial Decisions
14(9)
Tax Treaties
23(1)
Tax Periodicals
23(1)
Tax Services
24(2)
United States Tax Reporter
24(1)
Standard Federal Tax Reporter
24(1)
Federal Tax Coordinator 2d
25(1)
Law of Federal Income Taxation (Mertens)
25(1)
Tax Management Portfolios
26(1)
CCH Federal Tax Service
26(1)
Citator
26(4)
CCH Citator
27(1)
Research Institute of America Citator 2nd Series
28(2)
Computers as a Research Tool
30(1)
Statements on Responsibilities in Tax Practice
30(5)
Sample Work Papers and Client Letter
35(1)
Problem Materials
35
Discussion Questions
35(1)
Problems
36(4)
Case Study Problem
40(1)
Tax Research Problems
40
Corporate Formations and Capital Structure
1(1)
Organization Forms Available
2(6)
Sole Proprietorships
2(1)
Partnerships
3(2)
Corporations
5(2)
Limited Liability Companies
7(1)
Limited Liability Partnerships
7(1)
Check-the-Box Regulations
8(1)
Legal Requirements For Forming a Corporation
9(1)
Tax Considerations in Forming a Corporation
10(2)
Section 351: Deferring Gain or Loss Upon Incorporation
12(14)
The Property Requirement
13(1)
The Control Requirement
13(4)
The Stock Requirement
17(1)
Effect of Sec. 351 on the Transferors
17(3)
Tax Consequences to Transferee Corporation
20(1)
Assumption of the Transferor's Liabilities
21(3)
Other Considerations in A Sec. 351 Exchange
24(2)
Choice of Capital Structure
26(4)
Characterization of Obligations as Debt or Equity Capital
26(1)
Debt Capital
27(1)
Equity Capital
28(1)
Capital Contributions by Shareholders
29(1)
Capital Contributions by Nonshareholders
30(1)
Worthlessness of Stock or Debt Obligations
30(3)
Securities
30(2)
Unsecured Debt Obligations
32(1)
Tax Planning Considerations
33(2)
Avoiding Sec. 351
33(2)
Compliance and Procedural Considerations
35(1)
Reporting Requirements Under Sec. 351
35(1)
Problem Materials
35
Discussion Questions
35(1)
Issue Identification Questions
36(1)
Problems
37(4)
Comprehensive Problem
41(1)
Case Study Problems
42(1)
Tax Research Problems
42
The Corporate Income Tax
1(1)
Corporate Elections
2(3)
Choosing a Calendar or Fiscal Year
2(2)
Accounting Methods
4(1)
General Formula for Determining the Corporate Tax Liability
5(1)
Computing a Corporation's Taxable Income
5(16)
Differences Between Individual and Corporate Taxable Income
6(1)
Sales and Exchange of Property
7(1)
Business Expenses
8(6)
Special Deductions
14(6)
Exceptions for Closely-Held Corporations
20(1)
Computing a Corporation's Income Tax Liability
21(2)
General Rules
21(2)
Personal Service Corporations
23(1)
Controlled Groups of Corporations
23(7)
Why Special Rules are Needed
24(1)
What is a Controlled Group?
24(3)
Application of the Controlled Group Test
27(1)
Special Rules Applying to Controlled Groups
28(1)
Consolidated Tax Returns
28(2)
Tax Planning Considerations
30(3)
Compensation Planning for Shareholder-Employees
30(1)
Special Election to Allocate Reduced Tax Rate Benefits
31(1)
Using NOL Carryovers and Carrybacks
32(1)
Compliance and Procedural Considerations
33(7)
Estimated Taxes
33(3)
Requirements for Filing and Paying Taxes
36(1)
When the Return must be Filed
36(1)
Tax Return Schedules
37(3)
Problem Materials
40
Discussion Questions
40(1)
Issue Identification Questions
41(1)
Problems
42(6)
Tax Form/Return Preparation Problem
48(1)
Case Study Problems
49(1)
Tax Research Problems
49
Corporate Nonliquidating Distributions
1(1)
Nonliquidating Distributions In General
2(1)
Earnings and Profits (E&P)
3(5)
Current Earnings and Profits
3(3)
Distinction Between Current and Accumulated E&P
6(2)
Nonliquidating Property Distributions
8(5)
Consequences of Nonliquidating Property Distributions to the Shareholders
8(3)
Constructive Dividends
11(2)
Stock Dividends and Stock Rights
13(3)
Tax-Free Stock Dividends
14(1)
Tax-Free Stock Rights
15(1)
Effect of Nontaxable Stock Dividends on the Distributing Corporation
16(1)
Taxable Stock Dividends and Stock Rights
16(1)
Stock Redemptions
16(12)
Effect of the Redemption on the Shareholder
17(1)
Attribution Rules
18(2)
Substantially Disproportionate Redemptions
20(1)
Complete Termination of the Shareholder's Interest
21(2)
Redemptions Not Essentially Equivalent to a Dividend
23(1)
Partial Liquidations
23(2)
Redemptions to Pay Death Taxes
25(2)
Effect of Redemptions on the Distributing Corporation
27(1)
Preferred Stock Bailouts
28(2)
Sec. 306 Stock Defined
28(1)
Dispositions of Sec. 306 Stock
28(1)
Redemptions of Sec. 306 Stock
29(1)
Exceptions to Sec. 306 Treatment
30(1)
Stock Redemptions by Related Corporations
30(3)
Brother-Sister Corporations
30(1)
Parent-Subsidiary Corporations
31(2)
Tax Planning Considerations
33(3)
Avoiding Unreasonable Compensation
33(1)
Bootstrap Acquisitions
34(1)
Timing of Distributions
34(2)
Compliance and Procedural Considerations
36(1)
Corporate Reporting of Nondividend Distributions
36(1)
Agreement to Terminate Interest Under Sec. 302(b)(3)
36(1)
Problem Materials
37
Discussion Questions
37(1)
Issue Identification Questions
38(1)
Problems
38(6)
Case Study Problems
44(1)
Tax Research Problems
45
Other Corporate Tax Levies
1(1)
The Corporate Alternative Minimum Tax
2(13)
The General Formula
2(2)
Definitions
4(1)
Tax Preference Items
5(1)
Adjustments to Taxable Income
6(2)
Adjusted Current Earnings (ACE) Adjustment
8(5)
Minimum Tax Credit
13(1)
Tax Credits and the AMT
13(2)
Personal Holding Company Tax
15(9)
Personal Holding Company Defined
15(1)
Stock Ownership Requirement
16(1)
Passive Income Requirement
16(4)
Determining the PHC Penalty Tax
20(1)
Avoiding the PHC Designation and Tax Liability By Making Dividend Distributions
21(2)
PHC Tax Calculation
23(1)
Accumulated Earnings Tax
24(9)
Corporations Subject to the Penalty Tax
24(1)
Proving a Tax-Avoidance Purpose
25(1)
Evidence Concerning The Reasonableness of an Earnings Accumulation
25(5)
Determining the Accumulated Earnings Tax Liability
30(2)
Accumulated Earnings Tax Calculation
32(1)
Tax Planning Considerations
33(3)
Special AMT Elections
34(1)
Eliminating the ACE Adjustment
34(1)
Avoiding the Personal Holding Company Tax
34(1)
Avoiding the Accumulated Earnings Tax
35(1)
Compliance and Procedural Considerations
36(1)
Alternative Minimum Tax
36(1)
Personal Holding Company Tax
36(1)
Accumulated Earnings Tax
36(1)
Problem Materials
36
Discussion Questions
36(3)
Issue Identification Questions
39(1)
Problems
40(5)
Tax Form/Return Preparation Problem
45(1)
Case Study Problems
45(1)
Tax Research Problems
46
Corporate Liquidating Distributions
1(1)
Overview of Corporate Liquidations
2(3)
The Shareholder
2(1)
The Corporation
3(1)
Definition of a Complete Liquidation
3(2)
General Liquidation Rules
5(5)
Effects of Liquidating on the Shareholders
5(1)
Effects of Liquidating on the Liquidating Corporation
6(4)
Liquidation of a Controlled Subsidiary Corporation
10(3)
Requirements
10(1)
Effects of Liquidating on the Shareholders
11(1)
Effects of Liquidating on the Subsidiary Corporation
12(1)
Special Shareholder Reporting Issues
13(2)
Partially Liquidating Distributions
13(1)
Subsequent Assessments Against the Shareholders
14(1)
Open Versus Closed Transactions
15(1)
Installment Obligations Received by a Shareholder
15(1)
Special Corporate Reporting Issues
15(1)
Expenses of the Liquidation
15(1)
Treatment of Net Operating Losses
16(1)
Recognition of Gain or Loss When Property is Distributed in Retirement of Debt
16(1)
General Rule
16(1)
Satisfaction of the Subsidiary's Debt Obligations
16(1)
Tax Planning Considerations
17(2)
Timing the Liquidation Transaction
17(1)
Recognition of Ordinary Losses when a Liquidation Occurs
18(1)
Obtaining 80% Ownership to Achieve Sec. 332 Benefits
18(1)
Avoiding Sec. 332 to Recognize Losses
19(1)
Compliance and Procedural Considerations
19(1)
General Liquidation Procedures
19(1)
Section 332 Liquidations
20(1)
Plan of Liquidation
20(1)
Problem Materials
20
Discussion Questions
20(2)
Issue Identification Questions
22(1)
Problems
23(5)
Case Study Problems
28(1)
Tax Research Problems
28
Corporate Acquisitions and Reorganizations
1(1)
Taxable Acquisition Transactions
2(8)
Asset Acquisitions
2(2)
Stock Acquisitions
4(6)
Comparison of Taxable and Tax-Free Acquisitions
10(3)
Taxable and Tax-Free Asset Acquisitions
10(1)
Comparison of Taxable and Tax-Free Stock Acquisitions
11(2)
Types of Reorganizations
13(2)
Tax Consequences of Reorganizations
15(4)
Target or Transferor Corporation
15(1)
Acquiring or Transferee Corporation
16(1)
Shareholders and Security Holders
16(3)
Acquisitive Reorganizations
19(14)
Type A Reorganization
19(6)
Type C Reorganization
25(3)
Type D Reorganization
28(2)
Type B Reorganization
30(3)
Type G Reorganization
33(1)
Divisive Reorganizations
33(6)
Divisive Type D Reorganization
33(6)
Type G Divisive Reorganization
39(1)
Other Reorganization Transactions
39(2)
Type E Reorganization
39(1)
Type F Reorganization
40(1)
Judicial Restrictions on the Use of Corporate Reorganizations
41(2)
Continuity of Proprietary Interest
41(1)
Continuity of Business Enterprise
42(1)
Business Purpose Requirement
42(1)
Step Transaction Doctrine
43(1)
Tax Attributes
43(4)
Assumption of Tax Attributes
43(1)
Limitation on Use of Tax Attributes
44(3)
Tax Planning Considerations
47(1)
Why Use a Reorganization Instead of a Taxable Transaction?
47(1)
Avoiding the Reorganization Provisions
48(1)
Compliance and Procedural Considerations
48(1)
Section 338 Deemed Liquidations
48(1)
Plan of Reorganization
48(1)
Party to a Reorganization
48(1)
Ruling Requests
49(1)
Problem Materials
49
Discussion Questions
49(1)
Issue Identification Questions
50(1)
Problems
51(7)
Case Study Problems
58(1)
Tax Research Problems
59
Consolidated Tax Returns
1(1)
Source of the Consolidated Tax Return Rules
2(1)
Definition of an Affiliated Group
2(2)
Requirements
2(2)
Comparison with Controlled Group Definitions
4(1)
Should a Consolidated Return be Filed?
4(1)
Advantages of Filing a Consolidated Tax Return
4(1)
Disadvantages of Filing a Consolidated Tax Return
5(1)
Consolidated Taxable Income
5(4)
Income Included in the Consolidated Tax Return
6(1)
Affiliated Group Elections
7(1)
Termination of the Affiliated Group
8(1)
Computation of the Affiliated Group's Tax Liability
9(2)
Regular Tax Liability
9(1)
Corporate Alternative Minimum Tax Liability
9(1)
Consolidated Tax Credits
10(1)
Foreign Tax Credit
11(1)
Intercompany Transactions
11(7)
Property Transactions
11(5)
Other Intercompany Transactions
16(2)
Dividends Received by Group Members
18(1)
Exclusion Procedure
18(1)
Consolidated Dividends-Received Deduction
18(1)
Consolidated Charitable Contributions Deduction
19(1)
Net Operating Losses (NOLs)
20(8)
Current Year NOLs
20(1)
Carrybacks and Carryforwards of Consolidated NOLs
21(1)
Carryback of Consolidated NOL to Separate Return Year
22(1)
Carryforward of Consolidated NOL to Separate Return Year
23(1)
Special Loss Limitations
24(4)
Consolidated Capital Gains and Losses
28(3)
Section 1231 Gains and Losses
29(1)
Capital Gains and Losses
30(1)
Stock Basis Adjustments
31(1)
Tax Planning Considerations
32(1)
100% Dividends-Received Deduction Election
32(1)
Estimated Tax Payments
32(1)
Compliance and Procedural Considerations
33(2)
The Basic Election and Return
33(1)
Parent Corporation as Agent for the Affiliated Group
34(1)
Liability for Taxes Due
35(1)
Problem Materials
35
Discussion Questions
35(3)
Issue Identification Questions
38(1)
Problems
38(6)
Tax Form/Return Preparation Problem
44(1)
Case Study Problems
45(1)
Tax Research Problems
46
Partnership Formation and Operation
1(1)
Definition of a Partnership
2(2)
General and Limited Partnerships
2(2)
Overview of Taxation of Partnership Income
4(1)
Partnership Profits and Losses
4(1)
The Partner's Basis
4(1)
Partnership Distributions
5(1)
Tax Implications of Formation of a Partnership
5(7)
Contribution of Property
5(5)
Contribution of Services
10(1)
Organizational and Syndication Expenditures
11(1)
Partnership Elections
12(3)
Partnership Taxable Year
12(2)
Other Partnership Elections
14(1)
Partnership Reporting of Income
15(1)
Partnership Taxable Income
15(1)
Separately Stated Items
15(1)
Partnership Ordinary Income
16(1)
Partner Reporting of Income
16(4)
Partner's Distributive Share
16(1)
Special Allocations
17(3)
Basis for Partnership Interest
20(4)
Beginning Basis
20(1)
Effects of Liabilities
20(2)
Effects of Operations
22(2)
Special Loss Limitations
24(1)
At-Risk Loss Limitation
24(1)
Passive Activity Limitations
24(1)
Transactions Between a Partner and the Partnership
25(3)
Sales of Property
25(1)
Guaranteed Payments
26(2)
Family Partnerships
28(1)
Capital Ownership
28(1)
Donor-Donee Allocations of Income
29(1)
Tax Planning Considerations
29(1)
Timing of Loss Recognition
29(1)
Compliance and Procedural Considerations
30(2)
Reporting to the IRS and the Partners
30(1)
IRS Audit Procedures
31(1)
Problem Materials
32
Discussion Questions
32(1)
Issue Identification Questions
33(1)
Problems
33(7)
Tax Form/Return Preparation Problem
40(2)
Case Study Problems
42(1)
Tax Research Problems
43
Special Partnership Issues
1(1)
Nonliquidating Distributions
2(6)
Recognition of Gain
2(2)
Basis Effects of Distributions
4(3)
Holding Period and Character of Distributed Property
7(1)
Nonliquidating Distributions With Sec. 751
8(4)
Section 751 Assets Defined
8(1)
Exchange of Sec. 751 Assets and Other Property
9(3)
Terminating an Interest in a Partnership
12(13)
Liquidating Distributions
12(4)
Sale of a Partnership Interest
16(3)
Retirement or Death of a Partner
19(1)
Exchange of a Partnership Interest
20(1)
Income Recognition and Transfers of a Partnership Interest
21(1)
Termination of a Partnership
22(2)
Mergers and Consolidations
24(1)
Division of a Partnership
25(1)
Special Forms of Partnerships
25(6)
Tax Shelters and Limited Partnerships
25(1)
Publicly Traded Partnerships
26(1)
Limited Liability Companies
26(1)
Limited Liability Partnerships
27(1)
Electing Large Partnerships
28(3)
Optional Basis Adjustments
31(2)
Optional Adjustment on Transfers
31(1)
Optional Adjustment on Distributions
32(1)
Tax Planning Considerations
33(1)
Liquidating Distribution or Sale to Partners
33(1)
Problem Materials
33
Discussion Questions
33(1)
Issue Identification Questions
34(1)
Problems
35(9)
Case Study Problems
44(1)
Tax Research Problems
45
S Corporations
1(1)
Should an S Election Be Made?
3(1)
Advantages of S Corporation Treatment
3(1)
Disadvantages of S Corporation Treatment
3(1)
S Corporation Requirements
4(3)
Shareholder-Related Requirements
4(1)
Corporation-Related Requirements
5(2)
Election of S Corporation Status
7(5)
Making the Election
7(1)
Termination of the Election
8(4)
S Corporation Operations
12(6)
Taxable Year
12(1)
Accounting Method Elections
13(1)
Ordinary Income or Loss
13(2)
Special S Corporation Taxes
15(3)
Taxation of the Shareholder
18(5)
Income Allocation Procedures
18(1)
Loss and Deduction Pass-Through to Shareholders
19(3)
Family S Corporations
22(1)
Basis Adjustments
23(2)
Basis Adjustments to S Corporation Stock
23(1)
Basis Adjustments to Shareholder Debt
24(1)
S Corporation Distributions
25(5)
Corporations Having No Earnings and Profits
25(1)
Corporations Having Accumulated Earnings and Profits
26(4)
Other Rules
30(2)
Tax Preference Items and Other AMT Adjustments
30(1)
Transactions Involving Shareholders and Other Related Parties
30(1)
Fringe Benefits Paid to a Shareholder-Employee
31(1)
Tax Planning Considerations
32(2)
Election to Allocate Income Based on the S Corporation's Accounting Methods
32(1)
Increasing the Benefits from S Corporation Losses
33(1)
Passive Income Requirements
33(1)
Compliance and Procedural Considerations
34(3)
Making the Election
34(1)
Filing the Corporate Tax Return
35(1)
Estimated Tax Payments
35(1)
Consistency Rules
36(1)
Sample S Corporation Tax Return
36(1)
Problem Materials
37
Discussion Questions
37(1)
Issue Identification Questions
38(1)
Problems
39(6)
Tax Form/Return Preparation Problem
45(1)
Case Study Problems
46(1)
Tax Research Problems
46
The Gift Tax
1(1)
Concept of Transfer Taxes
2(1)
History and Purpose of Transfer Taxes
2(1)
The Unified Transfer Tax System
3(1)
Unified Rate Schedule
3(1)
Impact of Taxable Gifts on Death Tax Base
3(1)
Unified Credit
3(1)
Gift Tax Formula
4(2)
Determination of Gifts
4(1)
Exclusions and Deductions
4(1)
Gift-Splitting Election
4(1)
Cumulative Nature of Gift Tax
5(1)
Unified Credit
6(1)
Transfers Subject to the Gift Tax
6(9)
Transfers for Inadequate Consideration
7(1)
Statutory Exemptions from the Gift Tax
7(3)
Cessation of Donor's Dominion and Control
10(1)
Valuation of Gifts
11(2)
Gift Tax Consequences of Certain Transfers
13(2)
Exclusions
15(3)
Amount of the Exclusion
15(1)
Present Interest Requirement
16(2)
Gift Tax Deductions
18(4)
Marital Deduction
18(2)
Charitable Contribution Deduction
20(2)
The Gift-Splitting Election
22(1)
Computation of the Gift Tax Liability
23(1)
Effect of Previous Taxable Gifts
23(1)
Unified Credit Available
23(1)
Comprehensive Illustration
24(1)
Background Data
24(1)
Calculation of Tax Liability
25(1)
Basis Considerations for a Lifetime Giving Plan
25(2)
Property Received by Gift
26(1)
Property Received At Death
26(1)
Below-Market Loans: Gift and Income Tax Consequences
27(1)
General Rules
27(1)
Tax Planning Considerations
28(1)
Negative Aspects of Gifts
29(1)
Compliance and Procedural Considerations
29(3)
Filing Requirements
29(1)
Due Date
30(1)
Gift-Splitting Election
30(1)
Short-Form Gift Tax Return
30(1)
Liability for Tax
31(1)
Determination of Value
31(1)
Statute of Limitations
31(1)
Problem Materials
32
Discussion Questions
32(1)
Issue Identification Questions
33(1)
Problems
34(3)
Tax Form/Return Preparation Problems
37(1)
Case Study Problems
37(1)
Tax Research Problems
38
The Estate Tax
1(1)
Estate Tax Formula
2(3)
Gross Estate
2(1)
Deductions
3(1)
Adjusted Taxable Gifts and Tax Base
3(1)
Tentative Tax on Estate Tax Base
4(1)
Reduction for Post-1976 Gift Taxes
4(1)
Unified Credit
5(1)
Other Credits
5(1)
The Gross Estate: Valuation
5(3)
Date-of-Death Valuation
5(2)
Alternate Valuation Date
7(1)
The Gross Estate: Inclusions
8(9)
Comparison of Gross Estate with Probate Estate
8(1)
Property in Which the Decedent Had an Interest
9(1)
Dower or Curtesy Rights
9(1)
Transferor Provisions
10(3)
Annuities and Other Retirement Benefits
13(1)
Jointly Owned Property
14(1)
General Powers of Appointment
15(1)
Life Insurance
15(1)
Consideration Offset
16(1)
Recipient Spouse's Interest in QTIP Trust
17(1)
Deductions
17(5)
Debts and Funeral and Administration Expenses
17(1)
Losses
18(1)
Charitable Contribution Deduction
19(1)
Marital Deduction
20(2)
Deduction for Certain Interests in Family-Owned Business
22(1)
Computation of Tax Liability
22(3)
Taxable Estate and Tax Base
22(1)
Tentative Tax and Reduction for Post-1976 Gift Taxes
23(1)
Unified Credit
23(1)
Other Credits
23(2)
Comprehensive Illustration
25(1)
Background Data
25(1)
Calculation of Tax Liability
26(1)
Liquidity Concerns
26(3)
Deferral of Payment of Estate Taxes
26(2)
Stock Redemptions to Pay Death Taxes
28(1)
Special Use Valuation of Farm Real Property
29(1)
Generation-Skipping Transfer Tax
29(2)
Tax Planning Considerations
31(3)
Use of Inter Vivos Gifts
31(1)
Use of Exemption Equivalent
31(1)
What Size Marital Deduction is Best?
32(1)
Use of Disclaimers
33(1)
Role of Life Insurance
33(1)
Qualifying the Estate for Installment Payments
34(1)
Where to Deduct Administration Expenses
34(1)
Compliance and Procedural Considerations
34(2)
Filing Requirements
34(1)
Due Date
35(1)
Valuation
35(1)
Election of Alternate Valuation Date
35(1)
Documents to be Included with Return
35(1)
Problem Materials
36
Discussion Questions
36(1)
Issue Identification Questions
37(1)
Problems
37(4)
Comprehensive Problems
41(1)
Tax Form/Return Preparation Problems
41(2)
Case Study Problems
43(1)
Tax Research Problems
44
Income Taxation of Trusts and Estates
1(1)
Basic Concepts
2(2)
Inception of Trusts
2(1)
Inception of Estates
2(1)
Reasons for Creating Trusts
2(1)
Basic Principles of Fiduciary Taxation
3(1)
Principles of Fiduciary Accounting
4(3)
The Importance of Identifying Income and Principal
4(1)
Effects of State Law or Terms of Trust Instrument
5(1)
Principal and Income: The Uniform Act
5(1)
Categorization of Depreciation
6(1)
Formula for Taxable Income and Tax Liability
7(3)
Gross Income
7(1)
Deductions for Expenses
7(2)
Distribution Deduction
9(1)
Personal Exemption
9(1)
Credits
10(1)
Distributable Net Income
10(3)
Significance of DNI
10(1)
Definition of DNI
11(1)
Manner of Computing DNI
11(2)
Determining a Simple Trust's Taxable Income
13(3)
Allocation of Expenses to Tax-Exempt Income
13(1)
Determination of DNI and the Distribution Deduction
14(1)
Tax Treatment for Beneficiary
15(1)
Short-Cut Approach to Proving Correctness of Taxable Income
15(1)
Effect of a Net Operating Loss
15(1)
Effect of a Net Capital Loss
16(1)
Comprehensive Illustration: Determining a Simple Trust's Taxable Income
16(3)
Background Data
16(1)
Trustee's Fee
17(1)
Distribution Deduction and DNI
17(1)
Trust's Taxable Income
18(1)
Categorizing a Beneficiary's Income
18(1)
Determining Taxable Income for Complex Trusts and Estates
19(5)
Determination of DNI and the Distribution Deduction
19(1)
Tax Treatment for Beneficiary
20(3)
Effect of a Net Operating Loss
23(1)
Effect of a Net Capital Loss
24(1)
Comprehensive Illustration: Determining a Complex Trust's Taxable Income
24(3)
Background Data
24(1)
Trustee's Fee
24(1)
Distribution Deduction and Dni
25(1)
Trust's Taxable Income
26(1)
Additional Observations
26(1)
Income in Respect of a Decedent
27(2)
Definition and Common Examples
27(1)
Significance of IRD
27(2)
Grantor Trust Provisions
29(4)
Purpose and Effect
30(1)
Revocable Trusts
30(1)
Post-1986 Reversionary Interest Trusts
31(1)
Retention of Administrative Powers
31(1)
Retention of Economic Benefits
32(1)
Control of Others' Enjoyment
32(1)
Tax Planning Considerations
33(2)
Ability to Shift Income
33(1)
Timing of Distributions
34(1)
Property Distributions
34(1)
Choice of Year-End for Estates
34(1)
Deduction of Administration Expenses
35(1)
Compliance and Procedural Considerations
35(1)
Filing Requirements
35(1)
Due Date for Return and Tax
35(1)
Documents to be Furnished to IRS
35(1)
Sample Simple and Complex Trust Returns
36(1)
Problem Materials
36
Discussion Questions
36(1)
Issue Identification Questions
37(1)
Problems
37(2)
Tax Form/Return Preparation Problems
39(2)
Case Study Problems
41(1)
Tax Research Problems
41
Administrative Procedures
1(1)
Role of the Internal Revenue Service
2(1)
Enforcement and Collection
2(1)
Interpretation of the Statute
2(1)
Organization of the IRS
2(1)
Audits of Tax Returns
3(7)
Percentage of Returns Examined
3(1)
Selection of Returns for Audit
4(2)
Alternatives for a Taxpayer whose Return is Audited
6(3)
90-Day Letter
9(1)
Litigation
9(1)
Requests for Rulings
10(3)
Information to Be Included in Taxpayer's Request
11(1)
Will the IRS Rule?
11(1)
When Rulings are Desirable
12(1)
Due Dates and Penalties
13(4)
Due Dates for Returns
13(1)
Extensions
13(1)
Due Dates for Payment of the Tax
13(1)
Interest on Tax Not Timely Paid
14(1)
Penalties
15(2)
Estimated Taxes
17(3)
Payment Requirements
17(2)
Penalty for Underpaying Estimated Taxes
19(1)
Exceptions to the Penalty
20(1)
Other More Severe Penalties
20(5)
Negligence
20(1)
Substantial Understatement
21(2)
Civil Fraud
23(1)
Criminal Fraud
24(1)
Statute of Limitations
25(4)
General Three-Year Rule
26(1)
Six-Year Rule For Substantial Omissions
26(1)
When No Return is Filed
27(1)
Other Exceptions to Three-Year Rule
27(1)
Refund Claims
28(1)
Liability for Tax
29(2)
Joint Returns
29(1)
Transferee Liability
30(1)
Tax Practice Issues
31(3)
Statutory Provisions Concerning Tax Return Preparers
31(1)
Rules of Circular 230
32(1)
Tax Accounting and Tax Law
33(1)
Accountant-Client Privilege
34(1)
Problem Materials
34
Discussion Questions
34(1)
Issue Identification Questions
35(1)
Problems
36(2)
Case Study Problem
38(1)
Tax Research Problems
39
U.S. Taxation of Foreign-Related Transactions
1(124)
Jurisdiction to Tax
2(1)
Taxation of U.S. Citizens and Resident Aliens
3(10)
Foreign Tax Credit
3(5)
Foreign-Earned Income Exclusion
8(5)
Taxation of Nonresident Aliens
13(5)
Definition of Nonresident Alien
13(2)
Investment Income
15(1)
Trade or Business Income
16(2)
Taxation of U.S. People Doing Business Abroad
18(17)
Domestic Subsidiary Corporations
19(1)
Foreign Branches
19(1)
Foreign Corporations
19(3)
Controlled Foreign Corporations
22(8)
Special Foreign Corporation Forms
30(1)
Foreign Sales Corporations
31(3)
Domestic International Sales Corporations
34(1)
Tax Planning Considerations
35(4)
Deduction Versus Credit for Foreign Taxes
35(1)
Election to Accrue Foreign Taxes
36(1)
Special Earned Income Elections
37(1)
Tax Treaties
37(1)
Special Resident Alien Elections
38(1)
Compliance and Procedural Considerations
39(1)
Reporting the Foreign Tax Credit
39(1)
Reporting the Earned Income Exclusion
39(1)
Filing Requirements for Aliens and Foreign Corporations
39(1)
FSC and DISC Filing Requirements
40(1)
Problem Materials
40
Discussion Questions
40(1)
Issue Identification Questions
41(1)
Problems
42(4)
Tax Form/Return Preparation Problems
46(1)
Case Study Problems
47(1)
Tax Research Problems
47
APPENDICES
Appendix A Tax Research Working Paper File
A-1
Appendix B Completed Tax Forms
B-1
Appendix C MACRS and ACRS Tables
C-1
Appendix D Glossary
D-1
Appendix E Statements on Responsibilities in Tax Practice (SRTPs)
E-1
Appendix F Comparison of Tax Attributes for C Corporations, Partnerships, and S Corporations
F-1
Appendix G Credit for State Death Taxes
G-1
Appendix H Acturial Tables
H-1
Appendix I Index of Code Sections
I-1
Appendix J Index of Treasury Regulations
J-1
Appendix K Index of Government Promulgations
K-1
Appendix L Index of Court Cases
L-1
Appendix M Subject Index
M-1

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