Pearsons Federal Taxation 2019 Corporations Partnerships Estates Trusts 32nd Edition Rupert and Anderson EBOOK PDF Instant Download

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Pearsons Federal Taxation 2019 Corporations Partnerships Estates Trusts 32nd Edition Rupert and Anderson EBOOK PDF Instant Download

• Chapter 1 Tax Research
• Overview of Tax Research
• Steps in the Tax Research Process
• Importance of the Facts to the Tax Consequences
• Creating a Factual Situation Favorable to the Taxpayer
• The Sources of Tax Law
• The Legislative Process
• The Internal Revenue Code
• Treasury Regulations
• Administrative Pronouncements
• Judicial Decisions
• Tax Treaties
• Tax Periodicals
• Tax Services
• The Internet as a Research Tool
• Keyword Searches
• Search by Citation
• Noncommercial Internet Services
• Citators
• Using the Citator
• Professional Guidelines for Tax Services
• Treasury Department Circular 230
• AICPA’s Statements on Tax Standards
• Sample Work Papers and Client Letter
• Problem Materials
• Discussion Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problem
• Case Study Problem
• Tax Research Problems
• Chapter 2 Corporate Formations and Capital Structure
• Organization Forms Available
• Sole Proprietorships
• Partnerships
• Corporations
• Limited Liability Companies
• Limited Liability Partnerships
• Check-the-Box Regulations
• Legal Requirements and Tax Considerations Related to Forming a Corporation
• Legal Requirements
• Tax Considerations
• Section 351: Deferring Gain or Loss Upon Incorporation
• The Property Requirement
• The Control Requirement
• The Stock Requirement
• Effect of Sec. 351 on the Transferors
• Tax Consequences to Transferee Corporation
• Assumption of the Transferor’s Liabilities
• Other Considerations in a Sec. 351 Exchange
• Choice of Capital Structure
• Characterization of Obligations as Debt or Equity
• Debt Capital
• Equity Capital
• Capital Contributions by Shareholders
• Capital Contributions by Nonshareholders
• Worthlessness of Stock or Debt Obligations
• Securities
• Unsecured Debt Obligations
• Tax Planning Considerations
• Avoiding Sec. 351
• Compliance and Procedural Considerations
• Reporting Requirements Under Sec. 351
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problems
• Case Study Problems
• Tax Research Problems
• Chapter 3 The Corporate Income Tax
• Corporate Elections
• Choosing a Calendar or Fiscal Year
• Accounting Methods
• Determining a Corporation’s Taxable Income and Tax Liability
• Corporate Tax Rate
• Sales and Exchanges of Property
• Business Expenses
• Special Deductions
• Exceptions for Closely Held Corporations
• Controlled Groups of Corporations
• What Is a Controlled Group?
• Application of the Controlled Group Test
• Special Rules Applying to Controlled Groups
• Consolidated Tax Returns
• Tax Planning Considerations
• Compensation Planning for Shareholder-Employees
• Compliance and Procedural Considerations
• Estimated Taxes
• Requirements for Filing and Paying Taxes
• When the Return Must Be Filed
• Tax Return Schedules
• Financial Statement Implications
• Scope, Objectives, and Principles of ASC 740
• Temporary Differences
• Deferred Tax Assets and the Valuation Allowance
• Accounting for Uncertain Tax Positions
• Balance Sheet Classification
• Tax Provision Process
• Comprehensive Example – Year 1
• Comprehensive Example – Year 2
• Other Transactions
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problem
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Chapter 4 Corporate Nonliquidating Distributions
• Nonliquidating Distributions in General
• Earnings and Profits (E&P)
• Current Earnings and Profits
• Distinction Between Current and Accumulated E&P
• Nonliquidating Property Distributions
• Consequences of Nonliquidating Property Distributions to the Shareholders
• Consequences of Property Distributions to the Distributing Corporation
• Constructive Dividends
• Stock Dividends and Stock Rights
• Nontaxable Stock Dividends
• Nontaxable Stock Rights
• Effect of Nontaxable Stock Dividends on the Distributing Corporation
• Taxable Stock Dividends and Stock Rights
• Stock Redemptions
• Tax Consequences of the Redemption to the Shareholder
• Attribution Rules
• Substantially Disproportionate Redemptions
• Complete Termination of the Shareholder’s Interest
• Redemptions Not Essentially Equivalent to a Dividend
• Partial Liquidations
• Redemptions to Pay Death Taxes
• Effect of Redemptions on the Distributing Corporation
• Preferred Stock Bailouts
• Sec. 306 Stock Defined
• Dispositions of Sec. 306 Stock
• Redemptions of Sec. 306 Stock
• Exceptions to Sec. 306 Treatment
• Stock Redemptions by Related Corporations
• Brother-Sister Corporations
• Parent-Subsidiary Corporations
• Tax Planning Considerations
• Avoiding Unreasonable Compensation
• Bootstrap Acquisitions
• Timing of Distributions
• Compliance and Procedural Considerations
• Corporate Reporting of Nondividend Distributions
• Agreement to Terminate Interest Under Sec. 302(b)(3)
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problem
• Case Study Problems
• Tax Research Problems
• Chapter 5 Other Corporate Tax Levies
• Use of C Corporation to Avoid Income Taxes
• Personal Holding Company Tax
• Personal Holding Company Defined
• Stock Ownership Requirement
• Passive Income Requirement
• Calculating the PHC Tax
• Avoiding the PHC Designation and Tax Liability by Making Dividend Distributions
• PHC Tax Calculation
• Accumulated Earnings Tax
• Corporations Subject to the Penalty Tax
• Proving a Tax-Avoidance Purpose
• Evidence Concerning the Reasonableness of an Earnings Accumulation
• Calculating the Accumulated Earnings Tax
• Comprehensive Example
• Tax Planning Considerations
• Avoiding the Personal Holding Company Tax
• Avoiding the Accumulated Earnings Tax
• Compliance and Procedural Considerations
• Personal Holding Company Tax
• Accumulated Earnings Tax
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problems
• Case Study Problems
• Tax Research Problems
• Chapter 6 Corporate Liquidating Distributions
• Overview of Corporate Liquidations
• The Shareholder
• The Corporation
• Definition of a Complete Liquidation
• General Liquidation Rules
• Effects of Liquidating on the Shareholders
• Effects of Liquidating on the Liquidating Corporation
• Liquidation of a Controlled Subsidiary
• Overview
• Requirements
• Effects of Liquidating on the Shareholders
• Effects of Liquidating on the Subsidiary Corporation
• Special Reporting Issues
• Pertaining to Shareholders
• Pertaining to the Liquidating Corporation
• Recognition of Gain or Loss When Property Is Distributed in Retirement of Debt
• General Rule
• Satisfaction of the Subsidiary’s Debt Obligations
• Tax Planning Considerations
• Timing the Liquidation Transaction
• Recognition of Ordinary Losses When a Liquidation Occurs
• Obtaining 80% Ownership to Achieve Sec. 332 Benefits
• Avoiding Sec. 332 to Recognize Losses
• Compliance and Procedural Considerations
• General Liquidation Procedures
• Section 332 Liquidations
• Plan of Liquidation
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problems
• Case Study Problems
• Tax Research Problems
• Chapter 7 Corporate Acquisitions And Reorganizations
• Taxable Acquisition Transactions
• Asset Acquisitions
• Stock Acquisitions
• Comparison of Taxable and Nontaxable Acquisitions
• Taxable and Nontaxable Asset Acquisitions
• Comparison of Taxable and Nontaxable Stock Acquisitions
• Types of Reorganizations and Their Tax Consequences
• The Target or Transferor Corporation
• The Acquiring or Transferee Corporation
• Shareholders and Security Holders
• Acquisitive Reorganizations
• Type A Reorganization
• Type C Reorganization
• Type D Reorganization
• Type B Reorganization
• Type G Reorganization
• Divisive Reorganizations
• Divisive Type D Reorganization
• Divisive Type G Reorganization
• Other Reorganizations
• Type E Reorganization
• Type F Reorganization
• Judicial Restrictions on the Use of Corporate Reorganizations
• Continuity of Interest
• Continuity of Business Enterprise
• Business Purpose Requirement
• Step Transaction Doctrine
• Tax Attributes
• Assumption of Tax Attributes
• Limitation on Use of Tax Attributes
• Tax Planning Considerations
• Why Use a Reorganization Instead of a Taxable Transaction?
• Avoiding the Reorganization Provisions
• Compliance and Procedural Considerations
• Section 338 Election
• Plan of Reorganization
• Party to a Reorganization
• Ruling Requests
• Financial Statement Implications
• Taxable Asset Acquisition
• Nontaxable Asset Acquisition
• Stock Acquisition
• Pricing the Acquisition
• Net Operating Losses
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problems
• Case Study Problems
• Tax Research Problems
• Chapter 8 Consolidated Tax Returns
• Definition of an Affiliated Group
• Requirements
• Comparison with Controlled Group Definitions
• Consolidated Tax Return Election
• Consolidated Return Regulations
• Termination of Consolidated Tax Return Filing
• Consolidated Taxable Income
• Accounting Periods and Methods
• Income Included in the Consolidated Tax Return
• Calculation of Consolidated Taxable Income and Tax
• Intercompany Transactions
• Basic Concepts
• Matching and Acceleration Rules
• Applications of Matching and Acceleration Rules
• Relevance of Matching and Acceleration Rules
• Items Computed on a Consolidated Basis
• Charitable Contribution Deduction
• Net Sec. 1231 Gain or Loss
• Capital Gains and Losses
• Dividends-Received Deduction
• Regular Tax Liability
• Tax Credits
• Estimated Tax Payments
• Net Operating Losses (NOLs)
• Current Year NOL
• Carryovers of Consolidated NOLs
• Special Loss Limitations
• Stock Basis Adjustments
• Tiering Up of Stock Basis Adjustments
• Excess Loss Account
• Tax Planning Considerations
• Advantages of Filing a Consolidated Tax Return
• Disadvantages of Filing a Consolidated Tax Return
• Compliance and Procedural Considerations
• The Basic Election and Return
• Parent Corporation as Agent for the Consolidated Group
• Separate Entity Treatment of Intercompany Transactions
• Liability for Taxes Due
• Financial Statement Implications
• Intercompany Transactions
• SRLY Losses
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problem
• Tax Form/Return Preparation Problem
• Case Study Problem
• Tax Research Problems
• Chapter 9 Partnership Formation And Operation
• Definition of a Partnership
• General and Limited Partnerships
• Overview of Taxation of Partnership Income
• Partnership Profits and Losses
• The Partner’s Basis
• Partnership Distributions
• Tax Implications of Formation of a Partnership
• Contribution of Property
• Contribution of Services
• Organizational and Syndication Expenditures
• Partnership Elections
• Partnership Tax Year
• Other Partnership Elections
• Partnership Reporting of Income
• Partnership Taxable Income
• Separately Stated Items
• Partnership Ordinary Income
• Special Deductions and Limitations
• Partner Reporting of Income
• Partner’s Distributive Share
• Special Allocations
• Basis for Partnership Interest
• Beginning Basis
• Effects of Liabilities
• Effects of Operations
• Special Loss Limitations
• At-Risk Loss Limitation
• Passive Activity Limitations
• Limitation on Excess Business Losses
• Transactions Between a Partner and the Partnership
• Sales of Property
• Guaranteed Payments
• Family Partnerships
• Capital Ownership
• Donor-Donee Allocations of Income
• Tax Planning Considerations
• Timing of Loss Recognition
• Guaranteed Payments
• Compliance and Procedural Considerations
• Reporting to the IRS and the Partners
• IRS Audit Procedures
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problem
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Chapter 10 Special Partnership Issues
• Nonliquidating Distributions
• Recognition of Gain
• Basis Effects of Distributions
• Holding Period and Character of Distributed Property
• Nonliquidating Distributions with Sec. 751
• Section 751 Assets Defined
• Exchange of Sec. 751 Assets and Other Property
• Liquidating or Selling a Partnership Interest
• Liquidating Distributions
• Sale of a Partnership Interest
• Other Partnership Termination Issues
• Retirement or Death of a Partner
• Exchange of a Partnership Interest
• Income Recognition and Transfers of a Partnership Interest
• Termination of a Partnership
• Mergers and Consolidations
• Division of a Partnership
• Optional and Mandatory Basis Adjustments
• Adjustments on Transfers
• Adjustments on Distributions
• Special Forms of Partnerships
• Tax Shelters and Limited Partnerships
• Publicly Traded Partnerships
• Limited Liability Companies
• Limited Liability Partnerships
• Limited Liability Limited Partnership
• Tax Planning Considerations
• Liquidating Distribution or Sale to Partners
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problem
• Case Study Problem
• Tax Research Problems
• Chapter 11 S Corporations
• Should an S Election Be Made?
• Advantages of S Corporation Treatment
• Disadvantages of S Corporation Treatment
• S Corporation Requirements
• Shareholder-Related Requirements
• Corporation-Related Requirements
• Election of S Corporation Status
• Making the Election
• Termination of the Election
• S Corporation Operations
• Taxable Year
• Accounting Method Elections
• Ordinary Income or Loss and Separately Stated Items
• Special S Corporation Taxes
• Taxation of the Shareholder
• Income Allocation Procedures
• Income Pass-Though to Shareholders
• Loss and Deduction Pass-Through to Shareholders
• Family S Corporations
• Basis Adjustments
• Basis Adjustments to S Corporation Stock
• Basis Adjustments to Shareholder Debt
• S Corporation Distributions
• Corporations Having No Earnings and Profits
• Corporations Having Accumulated Earnings and Profits
• Other Rules
• Tax Preference Items and Other AMT Adjustments
• Transactions Involving Shareholders and Other Related Parties
• Fringe Benefits Paid to a Shareholder-Employee
• Tax Planning Considerations
• Election to Allocate Income Based on the S Corporation’s Accounting Methods
• Increasing the Benefits from S Corporation Losses
• Salary Levels
• Passive Income Requirements
• Compliance and Procedural Considerations
• Making the Election
• Filing the Corporate Tax Return
• Estimated Tax Payments
• Consistency Rules
• Sample S Corporation Tax Return
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problems
• Tax Form/Return Preparation Problems
• Case Study Problem
• Tax Research Problems
• Chapter 12 The Gift Tax
• The Unified Transfer Tax System
• History and Purpose of Transfer Taxes
• Unified Rate Schedule
• Impact of Taxable Gifts on Death Tax Base
• Unified Credit
• Gift Tax Formula
• Determination of Gifts
• Exclusions and Deductions
• Gift-Splitting Election
• Cumulative Nature of Gift Tax
• Unified Credit
• Transfers Subject to the Gift Tax
• Transfers for Inadequate Consideration
• Statutory Exemptions from the Gift Tax
• Cessation of Donor’s Dominion and Control
• Valuation of Gifts
• Gift Tax Consequences of Certain Transfers
• Exclusions
• Amount of the Exclusion
• Present Interest Requirement
• Gift Tax Deductions
• Marital Deduction
• Charitable Contribution Deduction
• The Gift-Splitting Election
• Computation of the Gift Tax Liability
• Effect of Previous Taxable Gifts
• Unified Credit Available
• Comprehensive Illustration
• Basis Considerations for a Lifetime Giving Plan
• Property Received by Gift
• Property Received at Death
• Below-Market Loans: Gift and Income Tax Consequences
• General Rules
• De Minimis Rules
• Tax Planning Considerations
• Tax-Saving Features of Inter Vivos Gifts
• Negative Aspects of Gifts
• Compliance and Procedural Considerations
• Filing Requirements
• Due Date
• Gift-Splitting Election
• Liability for Tax
• Determination of Value
• Statute of Limitations
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problems
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Chapter 13 The Estate Tax
• Estate Tax Formula
• Gross Estate
• Deductions
• Adjusted Taxable Gifts and Tax Base
• Tentative Tax on Estate Tax Base
• Reduction for Post-1976 Gift Taxes
• Unified Credit
• The Gross Estate: Valuation
• Date-of-Death Valuation
• Alternate Valuation Date
• The Gross Estate: Inclusions
• Comparison of Gross Estate with Probate Estate
• Property in Which the Decedent Had an Interest
• Dower or Curtesy Rights
• Transferor Provisions
• Annuities and Other Retirement Benefits
• Jointly Owned Property
• General Powers of Appointment
• Life Insurance
• Consideration Offset
• Recipient Spouse’s Interest in QTIP Trust
• Deductions
• Debts and Funeral and Administration Expenses
• Losses
• Charitable Contribution Deduction
• Marital Deduction
• Computation of Tax Liability
• Taxable Estate and Tax Base
• Tentative Tax and Reduction for Post-1976 Gift Taxes
• Unified Credit
• Portability Between Spouses of Exemption Amount
• Other Credits
• Comprehensive Illustration
• Liquidity Concerns
• Deferral of Payment of Estate Taxes
• Stock Redemptions to Pay Death Taxes
• Special Use Valuation of Farm Real Property
• Generation-Skipping Transfer Tax
• Tax Planning Considerations
• Use of Inter Vivos Gifts
• Use of Basic Exclusion Amount
• What Size Marital Deduction Is Best?
• Use of Disclaimers
• Role of Life Insurance
• Qualifying the Estate for Installment Payments
• Where to Deduct Administration Expenses
• Compliance and Procedural Considerations
• Filing Requirements
• Due Date
• Valuation
• Election of Alternate Valuation Date
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problems
• Tax Strategy Problems
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Chapter 14 Income Taxation Of Trusts And Estates
• Basic Concepts
• Inception of Trusts
• Inception of Estates
• Reasons for Creating Trusts
• Basic Principles of Fiduciary Taxation
• Principles of Fiduciary Accounting
• The Importance of Identifying Income and Principal
• Principal and Income: The Uniform Act
• Categorization of Depreciation
• Formula for Taxable Income and Tax Liability
• Gross Income
• Deductions for Expenses
• Distribution Deduction
• Personal Exemption
• Credits
• Distributable Net Income
• Significance of DNI
• Definition of DNI
• Manner of Computing DNI
• Determining a Simple Trust’s Taxable Income
• Allocation of Expenses to Tax-Exempt Income
• Determination of DNI and the Distribution Deduction
• Tax Treatment for Beneficiary
• Shortcut Approach to Proving Correctness of Taxable Income
• Effect of a Net Operating Loss
• Effect of a Net Capital Loss
• Comprehensive Illustration: Determining a Simple Trust’s Taxable Income
• Determining Taxable Income for Complex Trusts and Estates
• Determination of DNI and the Distribution Deduction
• Tax Treatment for Beneficiary
• Effect of a Net Operating Loss
• Effect of a Net Capital Loss
• Comprehensive Illustration: Determining a Complex Trust’s Taxable Income
• Income in Respect of a Decedent
• Definition and Common Examples
• Significance of IRD
• Grantor Trust Provisions
• Purpose and Effect
• Revocable Trusts
• Post-1986 Reversionary Interest Trusts
• Retention of Administrative Powers
• Retention of Economic Benefits
• Control of Others’ Enjoyment
• Tax Planning Considerations
• Ability to Shift Income
• Timing of Distributions
• Property Distributions
• Choice of Year-End for Estates
• Deduction of Administration Expenses
• Compliance and Procedural Considerations
• Filing Requirements
• Due Date for Return and Tax
• Documents to Be Furnished to IRS
• Sample Simple and Complex Trust Returns
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problems
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Chapter 15 Administrative Procedures
• Role of the Internal Revenue Service
• Enforcement and Collection
• Interpretation of the Statute
• Audits of Tax Returns
• Percentage of Returns Examined
• Selection of Returns for Audit
• Disclosure of Uncertain Tax Positions
• Alternatives for a Taxpayer Whose Return Is Audited
• 90-Day Letter
• Litigation
• Requests for Rulings
• Information to Be Included in Taxpayer’s Request
• Will the IRS Rule?
• When Rulings Are Desirable
• Due Dates
• Due Dates for Returns
• Extensions
• Due Dates for Payment of the Tax
• Interest on Tax Not Timely Paid
• Failure-to-File and Failure-to-Pay Penalties
• Failure to File
• Failure to Pay
• Estimated Taxes
• Payment Requirements
• Penalty for Underpaying Estimated Taxes
• Exceptions to the Penalty
• Other More Severe Penalties
• Negligence
• Substantial Understatement
• Transactions without Economic Substance
• Civil Fraud
• Criminal Fraud
• Statute of Limitations
• General Three-Year Rule
• Six-Year Rule for Substantial Omissions
• When No Return is Filed
• Other Exceptions to Three-Year Rule
• Refund Claims
• Liability for Tax
• Joint Returns
• Transferee Liability
• Tax Practice Issues
• Statutory Provisions Concerning Tax Return Preparers
• Reportable Transaction Disclosures
• Rules of Circular 230
• Statements on Standards for Tax Services
• Tax Accounting and Tax Law
• Accountant-Client Privilege
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problem
• Case Study Problem
• Tax Research Problems
• Chapter 16 U.S. Taxation of Foreign-Related Transactions
• The U.S. System of International Taxation
• Participation Exemption System
• Taxation of U.S. Citizens and Resident Aliens
• Foreign Tax Credit
• Foreign-Earned Income Exclusion
• Taxation of Nonresident Aliens
• Definition of Nonresident Alien
• Investment Income
• Trade or Business Income
• Taxation of U.S. Businesses Operating Abroad
• Domestic Subsidiary Corporations
• Foreign Branches
• Foreign Corporations
• Potential Deferral of Tax on Foreign Earnings
• Controlled Foreign Corporations
• Deemed Paid Foreign Tax Credit
• Transfer Pricing
• Inversions
• Tax Planning Considerations
• Deduction Versus Credit for Foreign Taxes
• Election to Accrue Foreign Taxes
• Special Earned Income Elections
• Tax Treaties
• Special Resident Alien Elections
• Compliance and Procedural Considerations
• Foreign Operations of U.S. Corporations
• Reporting the Foreign Tax Credit
• Reporting the Earned Income Exclusion
• Filing Requirements for Aliens and Foreign Corporations
• Financial Statement Implications
• Foreign Tax Credit
• Problem Materials
• Discussion Questions
• Issue Identification Questions
• Problems
• Comprehensive Problem
• Tax Strategy Problem
• Tax Form/Return Preparation Problems
• Case Study Problems
• Tax Research Problems
• Appendices