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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