Bankruptcy and Insolvency Taxation

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John Wiley & Sons, May 13, 2005 - Business & Economics - 768 pages
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The thousands of mergers, acquisitions, and start-ups that have characterized the past ten 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. Bankruptcy and Insolvency Taxation, Third Edition provides the answers to the questions financial managers will have on the tax aspects of the "bankruptcy strategy."
 

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Contents

Chapter 3 Partnerships and S Corporations Tax Impact of Workouts and Bankruptcies
1117
Chapter 4 Taxation of Bankruptcy Estates and Debtors
1151
Chapter 5 Corporate Reorganizations
1217
Chapter 6 Use of Net Operating Losses
1283
Chapter 7 Other Corporate Issues
1369
Chapter 8 State and Local Taxes
1409
Chapter 9 Tax Consequences to Creditors of Loss from Debt Forgiveness
1425
Chapter 10 Tax Procedures and Litigation
1455
Appendix B Senate Report No 961035 on HR 5043Bankruptcy Tax Act of 1980
1721
Appendix C Senate Proposed Amendments to HR 5043 Bankruptcy Tax Act of 1980 Adopted by Both Senate and House
1757
Appendix D Representative Ullmans Statement Regarding Bankruptcy Tax Legislation
1767
Appendix E Selected Provisions from the General Explanation of the Tax Reform Act of 1986 HR 3838 99th Congress Public Law 99514
1781
Appendix F Selected Provisions from the Explanation of the Technical and Miscellaneous Revenue Act of 1988
1829
Appendix G Tax Consequences of PlanRevco
1845
Statutes Citations
1851
Treasury Regulations Revenue Procedures and Revenue Rulings Citations
1857

Chapter 11 Tax Priorities and Discharge
1535
Chapter 12 Tax Preferences and Liens
1639
Appendix A Internal Revenue Code Selected Sections
1673

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About the author (2005)

Grant W. Newton, Professor of Accounting, Graziadio School of Business and Management, Pepperdine University, Malibu, California, is the author of Bankruptcy and Insolvency Accounting; Practice and Procedure (updated annually) and Corporate Bankruptcy (2003), also published by John Wiley & Sons. He is the Executive Director of the Association of Insolvency and Restructuring Advisors and he developed and teaches the three courses that lead to the Certified Insolvency and Restructuring Advisor (CIRA) designation. A CPA, CIRA, and CMA, he received a Ph.D. from New York University, a Master’s degree from the University of Alabama, and a B.S. Degree from the University of North Alabama.
Dr. Newton was a member of the AICPA’s Task Force on Financial Reporting by Entities in Reorganization Under the Bankruptcy Code that resulted in the issuance of the Statement of Position 90-7. He is coauthor of Consulting Services Practice Aid 02-1: Business Valuation in Bankruptcy and Providing Bankruptcy & Reorganization Services—Practice Aid, both published by the AICPA. He serves as a consultant and expert witness on issues dealing with financial reporting during and emerging from chapter 11, valuation, terms of plan, tax impact of plan, tax issues related to the bankruptcy estate, and recovery of assets.

Robert Liquerman is a principal in KPMG LLP’s Washington National Tax Practice, Corporate Tax Group, specializing in matters under Subchapter C of the Internal Revenue Code. He is an adjunct professor of law in the LL.M. program at the Georgetown University Law Center and previously served as an adjunct professor in the LL.M. program at The College of William & Mary, Marshall-Wythe School of Law. Mr. Liquerman holds an LL.M. in Taxation from New York University School of Law; a J.D. from St. John’s University, School of Law; and a B.S. in Accounting from the State University of New York at Binghamton.
He joined KPMG LLP from the Internal Revenue Service Office of the Chief Counsel, Corporate Division. In this position, he drafted treasury regulations, private letter rulings, technical advice memoranda, closing agreements, responses to congressional inquiries, field service advice, and memoranda of law. Prior to his government experience, Mr. Liquerman was a senior tax associate in the mergers and acquisition group and the insurance group in the New York office of Coopers & Lybrand.
He is a frequent speaker on bankruptcy and tax issues at various tax institutes and conferences around the country, including Tax Executives Institute, Federal Bar Association, DC Bar Association, and the Association of Insolvency and Restructuring Accountants. Mr. Liquerman is a member of the American Bar Association, Section of Taxation.
Although Chapters 2, 5, 6, and 7 reflect the views of Robert Liquerman, they do not necessarily reflect the views of KPMG, LLP.

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