Federal Corporate Taxation
Corporate Double Tax; Forming a Corporation; Corporation as a Taxable Entity; Cash and Property Distributions; Redemptions; Stock Dividends; Tainted Stock; liquidations; Taxable Acquisitions; Reorganizations; Combining Tax Attributes; Penalty Provisions; S Corporations.
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THE CORPORATE DOUBLE
FORMING A CORPORATION
THE CORPORATION AS A TAXABLE
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351 transaction 80 percent accumulated earnings acquiring corporation acquisition adjusted basis allocated alternative minimum tax amount apply appreciated assets assume attribution rules bailout boot capital gain carryover cash Commissioner common stock Congress Corp.'s corporate earnings corporate profits corporate tax debt instrument deduction deemed distributing corporation double tax earnings and profits effect election equity example exchange treatment fair market value gain or loss holder income tax individual infra interest investment leveraged buyout limitation liquidating corporation loan merger nonrecognition Note offset ordinary income outstanding ownership partial liquidation pass-thru passive income payments personal holding company poison pill preferred stock profits account provision purchase qualify for exchange received recharacterized recognize gain redeemed redemption Regs regulations reorganization requirement Section securities sells Service shareholder-level shareholders shares sold stock basis subchapter subsidiary Suppose X Corp supra target corporation tax avoidance tax rate tax-free taxable income taxation taxpayer tion transfer transferee-corporation transferor treated voting stock