Federal income taxation of corporations
Announcing the long-awaited revision of noted tax expert Bill Andrews; corporate tax casebook! New co-author Alan Feld joins Professor Andrews in meticulously updating FEDERAL INCOME TAXATION OF CORPORATE TRANSACTIONS to reflect the latest statutory changes through 1993, As well as new cases and developments in corporate tax. The Third Edition features: more international cases, such as Gulf Oil Corp. v. Commissioner, affording more opportunities to explore complex transactions numerous new cases selected for currency and pedagogy discussion of leveraged buyouts and related trends of the 1980s-put into perspective thorough treatment of the important new rate advantage for long term capital gains, especially with regard to discussion of redemption transactions This new edition maintains the overall organization of previous editions. The authors begin with a general introduction that deals with early stock dividend cases And The repeal of the General Utilities doctrine. They then consider reorganization and related non-recognized provisions-before examining distributions to shareholders and corporate taxable income. This very effective approach immerses students early in the interplay of complex transactions, statutes, and unpredictable interpretations; introduces court-made doctrines in their original setting; and gives students a realistic context for studying corporate tax concepts. For skillful analysis of corporate tax policy, adopt FEDERAL INCOME TAXATION OF CORPORATE TRANSACTIONS, Third Edition. Its insightful Teacher's Manual completes a truly outstanding teaching package.
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Introduction to the Corporate Income Tax
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50 percent 5th Cir accumulated earnings acquiring corporation acquisition adjusted basis agreement amount apply assets attribution rules bank boot capital gain cash Code Commissioner common stock Congress constructive dividend Corp corporate tax corporation's debt deduction determined distributing corporation earnings and profits election employees equity example exchange fair market value gain or loss held Helvering holder holding income tax interest investment issue KCorp leveraged buyout liability liquidation loan merger nonrecognition operating option ordinary income outstanding ownership paid partnership passive income payment petitioner preferred stock provides purchase purposes qualify received recognize gain redeemed redemption Regs regulations reorganization requirement result section 351 sell shareholder's shareholders shares stock dividend stockholders Stouffer subchapter subsidiary substantially Suppose supra target corporation tax avoidance tax consequences Tax Court tax-free taxable income taxation taxpayer tion transaction transfer transferor Treas treated treatment Uniroyal voting stock X Corp XCorp