What people are saying - Write a review
We haven't found any reviews in the usual places.
TAXATION OF C CORPORATIONS
The Capital Structure of a Corporation
4 other sections not shown
Other editions - View all
acquiring corporation acquisitive reorganization ADSP alternative minimum tax amount realized assets and liabilities assumed Bittker boot capital gain cash COD income Commissioner continuity of interest contributed property controlled corporation corporate law merger corporate level corporate tax shelters corporation stock deduction deemed sale discharge of indebtedness discharged debt distributing corporation dividend economic election exchange excluded discharge fair market value former T shareholders gain or loss Gitlitz and Winn gross income grossed-up indebtedness income insert Internal Revenue Code issued law merger statute loss tax attribute negative basis nonqualified preferred stock nonrecently purchased nonrecognition nonrecourse debt offset operating loss tax ordinary income Peracchi promissory note proposed regulations purchased T stock qualify redemption reduced requirement Revenue Ruling second full paragraph sell shareholder's spin-off subchapter S corporation suspended losses T's assets target corporation tax attribute reduction tax consequences Tax Court taxable Taxation Taxpayer Relief Act transferred treated Witzel