Fundamentals of Partnership Taxation

Author: Stephen Schwarz
Publisher: Foundation Press
ISBN: 9781609300692
Format: PDF, ePub, Docs
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The ninth edition of this leading casebook continues the long tradition of teaching the "fundamentals" of a highly complex subject through the use of clear and lively explanatory text, skillfully drafted problems, and a selective mix of original source materials to accompany the Code and regulations. Important highlights of the ninth edition include: * Coverage of all significant developments since the last edition, including proposed regulations interpreting the § 706 varying interest rule and defining "interest in a limited partnership" for purposes of the § 469 passive loss limitations. * A fresh perspective on choice of entity, including employment tax considerations for partners and LLC members. * New author's text discussing series LLCs and partnership debt-for-equity exchanges. * Revised text on special allocations under § 704(b) with a new section on target allocations. * An update on the partnership "carried interest" controvers

Fundamentals of Business Enterprise Taxation

Author: Stephen Schwarz
Publisher:
ISBN: 9781634596039
Format: PDF
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Offered as an alternative to the authors' widely used separate texts on corporate and partnership tax, the Sixth Edition of this comprehensive casebook continues its tradition of providing an integrated approach to teaching the "fundamentals" of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, selective discussion of tax policy issues, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the Sixth Edition include: Coverage of all significant C corporation and partnership developments since the last edition, including the impact of the now permanent higher marginal individual tax rates and the 3.8% net investment income tax; new legislation blocking tax-free spin-offs of REITs; final regulations on � 336(e) elections, Type F reorganizations, noncompensatory options, and partnership allocations where interests change during the year; and new proposed regulations on � 355 corporate divisions, partnership liabilities, � 751(b) disproportionate distributions, and disguised payments for services as applied to investment management fee waivers and similar strategies to convert ordinary income to capital gain. Updated and reorganized discussion of the continuity of proprietary interest doctrine in tax-free reorganizations. Integrated materials related to compensating the service partner in a new and fully updated self-standing chapter. Shorter separate chapters on partnership allocations, allocation of partnership liabilities, income-shifting safeguards, partner-partnership property transactions, liquidating distributions, and partnership terminations and mergers. A new case (Canal Corporation v. Commissioner) illustrating a successful IRS attack on the debt-financed distribution gain deferral strategy. Updated discussion of business enterprise tax policy issues, including a new overview of issues affecting U.S. multinational corporations, the latest prospects and options for comprehensive tax reform, and the ongoing debate on taxing partnership "carried interests." A completely updated chapter on S corporations, incorporating temporary Code provisions made permanent and final regulations on the basis of indebtedness of S corporations to their shareholders, and expanded coverage of employment tax issues affecting S corporation owners who are active in the business.

The Logic of Subchapter K

Author: Laura E. Cunningham
Publisher: West Academic
ISBN: 9780314199850
Format: PDF, Mobi
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This product is designed to guide students through the conceptual framework of subchapter K. The material avoids neither the hard questions nor the conceptual difficulties, leaving students with a firm understanding of partnership taxation. Each chapter begins with a basic explanation of the relevant provisions and the roles that they play in the overall structure of subchapter K. It includes an increasingly detailed discussion of the specific rules, including multiple illustrative examples. Each chapter builds on the earlier chapters, leading the student through subchapter K. It is appropriate for J.D. or graduate-level law school courses on partnership taxation.

Fundamentals of federal income taxation

Author: James J. Freeland
Publisher: Foundation Pr
ISBN:
Format: PDF, ePub, Mobi
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The Tenth Edition of Freeland, Lind & Stephens' Fundamentals of Federal Income Taxation incorporates changes made by 1996 & 1997 legislation including: * A new Chapter 11A dealing with the inclusion of gains on principal residences under Section 121 * A new Chapter 11C dealing with Exclusions & Other Tax Benefits Related to the Costs of Higher Education. These include the Sections 25A Hope & Lifetime Learning Credits, the Section 135 Savings Bond Exclusion Provision, the Section 529 Qualified State Tuition Programs & the Section 530 Educational IRAs * An addition to Chapter 20C to cover Roth IRAs & SIMPLE retirement plans * Changes in Chapter 21 dealing with Capital Gains & Losses to reflect the amendments to Section 1(h) & other legislative changes to the taxation of capital gains & losses * Consideration in Chapter 27B of the Qualified Adoption Expense Credit & the Child Credit

Tax Policy

Author: Philip D. Oliver
Publisher: Foundation Press
ISBN: 9781599416250
Format: PDF
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The third edition arrives at a time when political impasse in Washington combines with a graying population and trillion-dollar deficits: a combination that makes fundamental reform both appealing and seemingly impossible to attain. Study of the fascinating and important field of tax policy has never been more timely. The third edition retains the same broad outline of the second, and the same seventeen chapters. At the same time, substantial changes have been made. Tax law, and tax scholarship, never stand still. Most chapters have at least one new excerpt Chapter One has four, and several new subchapters have been added. These additions bring the book up to date, and pick up new strands of scholarly discussion. Throughout the book, the third edition gives increased emphasis to political considerations. Chapter One deals with the constraints on policy choices resulting from our unprecedented deficits, and from the even more threatening long-term commitments that our entitlement programs represent. In addition to bringing these problems into sharper relief, Chapter One now addresses the causes and consequences of the increasing inequality that has been affecting the entire world, including the United States, for the past thirty years. In other chapters, an array of new excerpts explore such topics as the psychological and economic factors that have led to our present version of the realization rule; the theoretical possibility of adjusting tax burdens to reflect different amenities in different areas of the country; intergenerational (in)equity as reflected in the Social Security tax-and-transfer program; and how our tax system which has never functioned well regarding inflation would function in a world of deflation. A new Table of Authorities has been added, which will aid the user in quickly finding excerpted

Federal Income Taxation of Corporations 3d 2010 Supplement

Author: Paul R. McDaniel
Publisher: Foundation Press
ISBN: 9781599418162
Format: PDF, ePub, Mobi
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This 2010 supplement updates the casebook, which provides detailed information on federal income taxation of corporations. The casebook provides the tools for fast, easy, on-point research and includes selected cases designed to illustrate the development of taxation of corporations.

Fundamentals of Modern Property Law

Author: Edward Rabin
Publisher: Foundation Press
ISBN: 9781609303266
Format: PDF, Docs
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The Seventh Edition of Fundamentals of Modern Property Law retains the highly successful problem method that has long characterized this landmark casebook: students take on the role of the lawyer in fact-rich hypothetical problems (Assignments) with multiple legal issues. Each Assignment builds students' lawyering skills of analysis and problem solving, as they master the fundamental principles and doctrines of property law. In addition, many Assignments are ideal for instructor-designed simulations of other professional skills, such as client interviewing and counseling, negotiation, oral advocacy, drafting, and objective and persuasive writing. The Seventh Edition continues the book's emphasis on emerging issues of environmental sustainability. The Seventh Edition also provides a comprehensive introduction to Intellectual Property law and emphasizes the art of planning to avoid controversy, in contrast to the typical first year curricular focus on resolving existing controversies.

Nonprofit Organizations Cases and Materials

Author: James Fishman
Publisher: Foundation Press
ISBN: 9781628101959
Format: PDF, Mobi
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The Fifth Edition of this pioneering casebook includes the usual rich mix of materials and is adaptable to a survey course, a policy-oriented seminar, or a more specialized J.D. or LL.M tax class. Every major topic is accompanied by a skillfully developed set of problems and includes lively notes, questions, and bibliographic references. Highlights of the Fifth Edition include: Coverage of all important developments since the last edition, including new state legislation and case law on nonprofit formation, governance, and donor standing; IRS scrutiny of colleges and universities, nonprofit executive compensation, and commercial activities; final tax regulations on the public charity support tests and supporting organizations; proposed regulations on the exemption requirements for hospitals and program-related investments; and recent antitrust litigation and other lawsuits challenging the NCAA's regulation of college athletes. Reorganized and updated coverage of the limitations on lobbying and political campaign activities of § 501(c)(3) charities; the use and abuse of noncharitable exempt organizations for political activities; and the implications of the Supreme Court's Citizens United decision on the nonprofit sector. Expanded discussion of the emerging forms of hybrid entities used for social enterprises that combine a public benefit mission with the pursuit of profit. A new and more contemporary introductory problem on the choices facing the founders of a nonprofit organization and revised problems on the state law duties of loyalty and care and the federal tax exemption standards for hospitals. A survey of proposed tax reform legislation affecting exempt organizations and the charitable deduction. Pruning of dated materials, minutia, and more tightly-edited cases, notes, and problems.