TAX RESEARCH
- Overview of Tax Research
- Steps in the Tax Research Process
- The Sources of Tax Law
- Tax Services
- Citators
- Computers as a Research Tool
- Statements on Standards for Tax Services
- Sample Work Papers and Client Letter
- Problem Materials
CORPORATE FORMATIONS AND CAPITAL STRUCTURE
- Organization Forms Available
- Check-the-Box Regulations
- Legal Requirements for Forming a Corporation
- Tax Considerations in Forming a Corporation
- Section 351: Deferring Gain or Loss Upon Incorporation
- Choice of Capital Structure
- Worthlessness of Stock or Debt Obligations
- Tax Planning Considerations
- Compliance and Procedural Considerations
- Financial Statement Implications
THE CORPORATE INCOME TAX
- Corporate Elections
- General Formula for Determining the Corporate Tax Liability
- Computing a Corporation’s Taxable Income
- Computing a Corporation’s Income Tax Liability
- Controlled Groups of Corporations
CORPORATE NONLIQUIDATING DISTRIBUTiONS
- Nonliquidating Distributions in General
- Earnings and Profits (E&P)
- Nonliquidating Property Distributions
- Stock Dividends And Stock Rights
- Stock Redemptions
- Preferred Stock Bailouts
- Stock Redemptions by Related Corporations
OTHER CORPORATE TAX LEVIES
- The Corporate Alternative Minimum Tax
- Personal Holding Company Tax
- Accumulated Earnings Tax
- Tax Planning Considerations
- Compliance and Procedural Considerations
- Financial Statement Implications
CORPORATE LIQUIDATING DISTRIBUTIONS
- Overview of Corporate Liquidations
- General Liquidation Rules
- Liquidation of a Controlled Subsidiary Corporation
- Special Shareholder Reporting Issues
- Special Corporate Reporting Issues
- Recognition of Gain or Loss When Property is Distributed in Retirement of Debt
CORPORATE ACQUISITIONS AND REORGANIZATIONS
- Taxable Acquisition Transactions
- Comparison of Taxable and Nontaxable Acquisitions
- Types of Reorganizations
- Tax Consequences of Reorganizations
- Acquisitive Reorganizations
- Divisive Reorganizations
- Other Reorganizations
- Judicial Restrictions on the Use of Corporate Reorganizations
- Tax Attributes
- Financial Statement Implications
CONSOLIDATED TAX RETURNS
- Source of the Consolidated Tax Return Rules
- Definition of an Affiliated Group
- Should a Consolidated Return Be Filed?
- Consolidated Taxable Income
- Computation of the Affiliated Group’s Taxliability
- Intercompany Transactions
- Dividends Received by Group Members
- Consolidated Charitable Contributions Deduction
- Net Operating Losses (NOLs)
- Consolidated Capital Gains and Losses
- Stock Basis Adjustments
PARTNERSHIP FORMATION AND OPERATION
- Definition ‘of a Partnership
- Overview of Taxation of Partnership Income
- Tax Implications of Formation of a Partnership
- Partnership Elections
- Partnership Reporting of Income
- Partner Reporting of Income
- Basis For Partnership Interest
- Special Loss Limitations
- Transactions Between a Partner and the Partnership
- Family Partnerships
SPECIAL PARTNERSHIP ISSUES
- Nonliquidating Distributions
- Nonliquidating Distributions with Sec. 751
- Terminating an Interest in a Partnership
- Optional and Mandatory Basis Adjustments
- Special Forms of Partnerships
S CORPORATIONS
- Should an S Election Be Made?
- S Corporation Requirements
- Election of S Corporation Status
- S Corporation Operations
- Taxation of the Shareholder
- Basis Adjustments
- S Corporation Distributions
- Other Rules
THE GIFT TAX
- Concept of Transfer Taxes
- The Unified Transfer Tax System
- Gift Tax Formula
- Transfers Subject to the Gift Tax
- Exclusions
- Gift Tax Deductions
- The Gift-Splitting Election
- Computation of the Gift Tax Liability
- Comprehensive Illustration
- Basis Considerations for a Lifetime Giving Plan
- Below-Market Loans: Gift and Income Tax Consequences
THE ESTATE TAX
- Estate Tax Formula
- The Gross Estate: Valuation
- The Gross Estate: Inclusions
- Deductions
- Computation of Tax Liability
- Comprehensive Illustration
- Liquidity Concerns
- Generation-Skipping Transfer Tax
INCOME TAXATION OF TRUSTS AND ESTATES
- Basic Concepts
- Principles of Fiduciary Accounting
- Formula for Taxable Income and Tax Liability
- Distributable Net Income
- Determining A Simple Trust’s Taxable Income
- Comprehensive Illustration: Determining a Simple Trust’s Taxable Income
- Determining Taxable Income for Complex Trusts and Estates
- Comprehensive Illustration: Determining a Complex Trust’s Income
- Income in Respect of a Decedent
- Grantor Trust Provisions
ADMINISTRATIVE PROCEDURES
- Role of the Internal Revenue Service
- Audits of Tax Returns
- Requests For Rulings
- Due Dates
- Failure-to-File and Failure-to-Pay Penalties
- Estimated Taxes
- Other More Severe Penalties
- Statute of Limitations
- Liability for Tax
- Tax Practice Issues
Tables and Forms
Tax Table and Rate Schedules
Tax Research Working Paper File
Completed Tax Forms
MACRS and ACRS Tables
Statements on Responsibilities in Tax Practice (SRTPs)
Comparison of Tax Attrributes for C Corporations, Partnerships, and S Corporations
Credit for State Death Taxes
Actuarial Tables
