Bankruptcy and Insolvency TaxationThe thousands of mergers, acquisitions, and start-ups that have characterized the past years of business have created an increasing number of corporations in financial trouble: specifically, a shortage of venture capital or quick cash. Consequently, bankruptcy protection is now viewed as a strategic move to protect corporations from their creditors and allow them to reorganize. Fully revised and updated with new case studies and the latest coverage of regulations, Bankruptcy and Insolvency Taxation, Fourth Edition provides the answers to the questions financial managers will have on the tax aspects of bankruptcy strategy. |
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Contents
Use of Net Operating Losses | |
a Introduction | |
R C Section 362e 432 | |
f Proposed I R C Section 336e Regulations 439 | |
c Qualified Stock Purchase 442 | |
i Election Procedures 453 | |
b Liquidating Trusts 466 | |
Section 108e8 i Background | |
Indebtedness Income | |
b Insolvency Exclusion | |
d Qualified Real Property Business Indebtedness Exclusion | |
b Net Operating Loss Reduction | |
e Alternative Minimum Taxable Income | |
d Treasury Decision 9497 Temporary Regulation | |
e Treasury Decision 9498 Temporary Regulation | |
b Discharge of Nonrecourse Debt | |
a Consolidated Return Issues | |
Inbound Transactions | |
Partnerships and S Corporations | |
Taxation of Bankruptcy Estates | |
ESTATE | |
Corporate Reorganizations | |
REORGANIZATIONS UNDER SECTION 368 | |
State and Local Taxes | |
Tax Consequences to Creditors | |
Tax Procedures and Litigation | |
Tax Priorities and Discharge | |
Tax Preferences and Liens | |
About the Authors | |
Treasury Regulations Revenue Procedures | |
Subject Index | |
Internal Revenue Code Selected Sections | |
CORPORATE LIQUIDATIONS SEC 332 COMPLETE LIQUIDATIONS | |
TRANSFER TO CORPORATION | |
RECEIPT OF ADDITIONAL | |
INDEBTEDNESS INCOME | |
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Common terms and phrases
9th Cir acquiring corporation acquisition adjusted aff’d allocated amount apply assets attribute reduction Bankr Bankruptcy Code bankruptcy court held bankruptcy estate bankruptcy petition built-in gain capital carryback chapter 11 COBE Commissioner consolidated group corporation’s court noted creditors debt discharge debtor debtor in possession deduction deemed determined discharge of indebtedness distribution district court DOI income election entity example exchange fair market value final regulations G reorganization I.R.C. section income tax insolvent interest IRS’s liquidation loss corporation nonrecourse nonrecourse debt ownership change partnership payment penalty percent period petition was filed postpetition preferred stock prepetition prior priority private letter rulings proof of claim provides purchase pursuant qualified received refund result rule section 382 limitation secured shareholders subsidiary target corporation tax attributes tax claim Tax Court tax liability tax lien tax return taxable taxpayer temporary regulations transaction transfer Treas treated trustee unsecured claims
Bibliographic information
| Title | Bankruptcy and Insolvency Taxation Volume 576 of Wiley Corporate F&A |
| Authors | Grant W. Newton, Robert Liquerman |
| Edition | 4, illustrated |
| Publisher | John Wiley & Sons, 2012 |
| ISBN | 1118172965, 9781118172964 |
| Length | 864 pages |
| Subjects | › › Business & Economics / General Business & Economics / Taxation / Corporate |
| Export Citation | BiBTeX EndNote RefMan |