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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