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| 자료유형 | 단행본 |
|---|---|
| 서명/저자사항 | Prentice Hall's federal taxation, 2003 - Corporations, Partnerships, Estates, and Trusts / editors, Kenneth E. Anderson, Thomas R. Pope, John L. Kramer |
| 개인저자 | Anderson, Kenneth E./ Pope, Thomas R./ Kramer, John L. |
| 발행사항 | Upper Saddle River, N.J. : Prentice Hall, 2003 |
| 형태사항 | v.p. : ill. ; 29 cm + CD-ROM 1 sheet |
| ISBN | 0130647462 |
| 서지주기 | Includes index |
| 비통제주제어 | Income tax/,Taxation |
| 분류기호 | 329.4042 |
| 언어 | 영어 |
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| 1 | M0292741 | 329.4042 P927 -2003,2 | 삼성캠퍼스/종합자료실/ | 대출가능 |
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목차
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CONTENTS
PREFACE ... xiii
CHAPTER 1 TAX RESEARCH ... 1-1
Overview of Tax Research ... 1-2
Steps in the Tax Research Process ... 1-3
Importance of the Facts to the Tax Consequences ... 1-5
...
목차 전체
CONTENTS
PREFACE ... xiii
CHAPTER 1 TAX RESEARCH ... 1-1
Overview of Tax Research ... 1-2
Steps in the Tax Research Process ... 1-3
Importance of the Facts to the Tax Consequences ... 1-5
Ability to Create a Factual Situation Favoring the Taxpayer ... 1-6
The Sources of Tax Law ... 1-7
The Legislative Process ... 1-7
The Internal Revenue Code ... 1-8
Treasury Regulations ... 1-8
Administrative Interpretations ... 1-11
Judicial Decisions ... 1-14
Tax Treaties ... 1-24
Tax periodicals ... 1-24
Tax Services ... 1-25
United States Tax Reporter ... 1-25
Standard Federal Tax Reporter ... 1-26
Federal Tax Coordinator 2d ... 1-26
Law of Federal Income Taxation (Mertens) ... 1-27
Tax Management Portfolios ... 1-27
Cch Federal Tax Service ... 1-28
Citators ... 1-28
CCH Citator ... 1-28
Research institute of America Citator 2nd Series ... 1-31
Computers as a Research Tool ... 1-34
Statements on Standards for Tax Services ... 1-35
Problem Materials ... 1-38
Sample Work Papers and Client Letter ... 1-38
Discussion Questions ... 1-38
Problems ... 1-40
Comprehensive Problem ... 1-43
Tax Strategy Problem ... 1-43
Case Study Problem ... 1-43
Tax Research Problems ... 1-43
CHAPTER 2 CORPORATE FORMATIONS AND CAPITAL STRUCTURE ... 2-1
Organization Forms Available ... 2-2
Sole Proprietorships ... 2-2
Partnerships ... 2-3
Corporations ... 2-5
Limited Liability Companies ... 2-7
Limited Liability Partnerships ... 2-7
Check-the-box Regulations ... 2-8
Tax Considerations in Forming a Corporation ... 2-9
Legal Requirements for Forming a Corporation ... 2-9
Section 351 : Deferring Gain or Loss Upon Incorporation ... 2-12
The Property Requirement ... 2-12
The Control Requirement ... 2-13
The Stock Requirement ... 2-16
Effect of Sec. 351 on the Trasferors ... 2-16
Tax Consequences to Transferee Corporation ... 2-20
Assumption of the Transferorus Liabilities ... 2-21
Other Considerations in a Sec. 351 Exchange ... 2-24
Choice of Capital Structure ... 2-26
Characterization of Obligations as Debt or Equity Capital ... 2-26
Debt Capital ... 2-27
Equity Capital ... 2-28
Capital Contributions By Shareholders ... 2-28
Worthlessness of Stock or Debt Obligations ... 2-30
Capital Contributions By Nonshareholders ... 2-30
Securities ... 2-30
Unsecured Debt Obligations ... 2-32
Tax Planning Considerations ... 2-33
Avoiding Sec. 351 ... 2-33
Compliance and Procedural Considerations ... 2-35
Reporting Requirements Under Sec. 351 ... 2-35
Problem Materials ... 2-35
Discussion Questions ... 2-35
Issue Identification Questions ... 2-36
Problems ... 2-37
Comprehensive Problem ... 2-41
Tax Strategy Problem ... 2-42
Case Study Problem ... 2-42
Tax Research Problem ... 2-43
CHAPTER 3 THE CORPORATE INCOME TAX ... 3-1
Corporate Elections ... 3-2
Choosing a Calendar or Fiscal Year ... 3-2
Accounting Methods ... 3-4
General Formula for Determining the Corporate Tax Liability ... 3-5
Computing a Corporationus Taxable Income ... 3-5
Sales and Exchanges of Property ... 3-6
Business Expenses ... 3-7
Special Deductions ... 3-12
Exceptions for Closely-held Corporations ... 3-18
Computing a Corporationus Income Tax Liability ... 3-20
General Rules ... 3-20
Personal Service Corporations ... 3-22
Controlled Groups of Corporations ... 3-22
Why Special Rules Are Needed ... 3-22
What Is a Controlled Group ... 3-23
Application of the Controlled Group Test ... 3-26
Special Rules Applying to Controlled Groups ... 3-26
Consolidated Tax Returns ... 3-27
Tax Planning Considerations ... 3-28
Compensation Planning for Shareholder-Employees ... 3-28
Special Election to Allocate Reduced Tax Rate Benefits ... 3-29
Using Nol Carryovers and Carrybacks ... 3-31
Compliance and Procedural Considerations ... 3-31
Estimated Taxes ... 3-31
Requirements for Filing and Paying Taxes ... 3-34
When the Return must be Filed ... 3-35
Tax Return Schedules ... 3-35
Problem Materials ... 3-38
Discussion Questions ... 3-38
Issue Identification Questions ... 3-39
Problems ... 3-39
Comprehensive Problem ... 3-45
Tax Strategy Problem ... 3-46
Tax Form／Return Preparation Problem ... 3-46
Case Study Problems ... 3-47
Tax Research Problems ... 3-48
CHAPTER 4 CORPORATE NONLIQUIDATING DISTRIBUTIONS ... 4-1
Nonliquidating Distributions in General ... 4-2
Current Earnings and Profits ... 4-3
Distinction Between Current and Accumulated E&P ... 4-6
Earnings and Profits (E&P) ... 4-3
Nonliquidating Property Distributions ... 4-8
Consequences of Nonliquidating Property Distributions to the Shareholders ... 4-8
Consequences of Property Distributions to the Distributing Corporation ... 4-9
Constructive Dividends ... 4-11
Stock Dividends and Stock Rights ... 4-13
Tax-free Stock Dividends ... 4-14
Tax-free Stock Rights ... 4-15
Effect of Nontaxable Stock Dividends on the Distributing Corporation ... 4-16
Taxable Stock Dividends and Stock Rights ... 4-16
Stock Redemptions ... 4-16
Effect of the Redemption on the Shareholder ... 4-17
Attribution Rules ... 4-18
Substantially Disproportionate Redemptions ... 4-20
Complete Termination of the Shareholderus Interest ... 4-21
Redemptions Not Essentially Equivalent to A Dividend ... 4-23
Partial Liquidations ... 4-24
Redemptions to Pay Death Taxes ... 4-25
Effect of Redemptions on The Distributing Corporation ... 4-27
Preferred Stock Bailouts ... 4-28
Sec. 306 Stock Defined ... 4-28
Dispositions of Sec. 306 Stock ... 4-29
Redemptions of Sec. 306 Stock ... 4-29
Exceptions to Sec. 306 Treatment ... 4-30
Stock Redemptions By Related Corporations ... 4-30
Brother-sister Corporations ... 4-30
Parent-subsidiary Corporations ... 4-32
Tax Planningconsiderations ... 4-33
Avoiding Unreasonable Compensation ... 4-33
Bootstrap Acquisitions ... 4-34
Timing of Distributions ... 4-35
Compliance and Procedural Considerations ... 4-36
Corporate Reporting of Nondividend Distributions ... 4-36
Agreement to Terminate Interest Under Sec. 302 (b)(3) ... 4-36
Problem Materials ... 4-37
Discussion Questions ... 4-37
Issue Identification Questions ... 4-38
Problems ... 4-39
Comprehensive Problems ... 4-45
Tax Strategy Problems ... 4-46
Case Study Problems ... 4-46
Tax Research Problems ... 4-46
CHAPTER 5 OTHER CORPORATE TAX LEVIES ... 5-1
The Corporate Alternative Minimum Tax ... 5-2
The General Formula ... 5-2
Definitions ... 5-4
Tax Preference Items ... 5-6
Adjustments to Taxable Income ... 5-7
Adjusted Current Earnings (Ace) Adjustment ... 5-9
Minimum Tax Credit ... 5-13
Tax Credits and the AMT ... 5-14
Personal Holding Company ... 5-15
Personal Holding Company Defined ... 5-16
Stock Ownership Requirement ... 5-16
Passive Income Requirement ... 5-16
Determining the PHC Penalty Tax ... 5-21
Avoiding the PHC Designation and Tax Liability By Making Dividend Distributions ... 5-22
PHC Tax Calculation ... 5-23
Accumulated Earnings Tax ... 5-24
Corporations Subject to the Penalty Tax ... 5-24
Proving a Tax-Avoidance Purpose ... 5-25
Evidence Concerning the Reasonableness of an Earnings Accumulation ... 5-26
Determining the Accumulated Earnings Tax Liability ... 5-31
Accumulated Earnings Tax Calculation ... 5-33
Tax Planning Considerations ... 5-35
Special Amt Elections ... 5-35
Eliminating the ACE Adjustment ... 5-35
Avoiding the Personal Holding Company Tax ... 5-36
Avoiding the Accumulated Earnings Tax ... 5-26
Compliance and Procedural Considerations ... 5-37
Alternative Minimum Tax ... 5-37
Personal Holding Company Tax ... 5-37
Accumulated Earnings Tax ... 5-37
Problem Materials ... 5-38
Discussion Questions ... 5-38
Issue Identification Questions ... 5-41
Problems ... 5-41
Comprehensive Problem ... 5-47
Tax Strategy Problem ... 5-48
Tax Form／Return Preparation Problem ... 5-48
Case Study Problems ... 5-49
Tax Research Problems ... 5-50
CHAPTER 6 CORPORATE LIQUIDATING DISTRIBUTIONS ... 6-1
Overview of Corporate Liquidations ... 6-2
The Shareholder ... 6-2
The Corporation ... 6-3
Definition of a Complete Liquidation ... 6-3
General Liquidation Rules ... 6-5
Effects of Liquidating on the Shareholders ... 6-5
Effects of Liquidating on the Liquidating Corporation ... 6-6
Liquidation of a Controlled Subsidiary Corporation ... 6-10
Requirements ... 6-10
Effects of Liquidating on the Shareholders ... 6-11
Effects of Liquidating on the Subsidiary Corporations ... 6-13
Special Shareholder Reporting Issues ... 6-14
Partially Liquidating Distributions ... 6-14
Subsequent Assessments Against the Shareholders ... 6-15
Open Versus Closed Transactions ... 6-15
Installment Obligationreceived By a Shareholder ... 6-15
Special Corporate Reporting Issues ... 6-16
Expenses of the Liquidation ... 6-16
Treatment of Net Operating Losses ... 6-16
Recognition of Gain or Loss When Property Is Distributed in Retirement of Debt ... 6-17
General Rule ... 6-17
Satisfaction of the Subsidiary Debt Obligations ... 6-17
Tax Planning Considerations ... 6-18
Timing the Liquidation Transaction ... 6-18
Recognition of Ordinary Losses When a Liquidation Occurs ... 6-18
Obtaining 80% Ownership to Achieve Sec. 332 Benefits ... 6-19
Avoiding Sec. 332 to Recognize Losses ... 6-19
Compliance and Procedural Considerations ... 6-20
General Liquidation Procedures ... 6-20
Section 332 Liquidations ... 6-20
Plan of Liquidation ... 6-21
Problem Materials ... 6-21
Discussion Questions ... 6-21
Issue Identification Questions ... 6-23
Problems ... 6-23
Comprehensive Problem ... 6-29
Tax Strategy Problem ... 6-30
Case Study Problems ... 6-31
Tax Research Problems ... 6-32
CHAPTER 7 CORPORATE ACQUISITIONS AND REORGANIZATIONS ... 7-1
Taxable Acquisition Transactions ... 7-2
Asset Acquisitions ... 7-2
Stock Acquisitions ... 7-4
Comparison of Taxable and Tax-free Acquisitions ... 7-11
Taxable and Tax-Free Asset Acquisitions ... 7-11
Comparison of Taxable and Tax-Free Stock Acquisitions ... 7-12
Types of Reorganizations ... 7-15
Tax Consequences of Reorganizations ... 7-16
Target or Transferor Corporation ... 7-16
Acquiring or Transferee Corporation ... 7-17
Shareholders and Security Holders ... 7-18
Acquisitive Reorganizations ... 7-21
Type A Reorganization ... 7-21
Type C Reorganization ... 7-28
Type D Reorganization ... 7-30
Type B Reorganization ... 7-31
Type G Reorganization ... 7-35
Divisive Reorganizations ... 7-35
Divisive Type D Reorganization ... 7-37
Type G Divisive Reorganization ... 7-41
Other Reorganization Transactions ... 7-41
Type E Reorganization ... 7-41
Type F Reorganization ... 7-43
Judicial Restrictions on The Use of Corporate Reorganizations ... 7-43
Continuity of Proprietary Interest ... 7-43
Continuity of Business Enterprise ... 7-44
Business Purpose Requirement ... 7-45
Step Transaction Doctrine ... 7-45
Tax Attributes ... 7-46
Assumption of Tax Attributes ... 7-46
Limitation on Use of Tax Attributes ... 7-47
Tax Planning Considerations ... 7-49
Why Use a Reorganization Instead of a Taxable Transaction? ... 7-49
Avoiding the Reorganization Provisions ... 7-50
Compliance and Procedural Considerations ... 7-51
Section 338 Election ... 7-51
Plan of Reorganization ... 7-51
Party to a Reorganization ... 7-51
Ruling Requests ... 7-51
Problem Materials ... 7-52
Discussion Questions ... 7-52
Issue Identification Questions ... 7-53
Problems ... 7-54
Comprehensive Problem ... 7-61
Tax Strategy Problems ... 7-62
Case Study Problems ... 7-63
Tax Research Problems ... 7-64
CHAPTER 8 CONSOLIDATED TAX RETURNS ... 8-1
Source of the Consolidated Tax Return Rules ... 8-2
Definition of an Affiliated Group ... 8-2
Requirements ... 8-2
Comparison with Controlled Group Definitions ... 8-4
Should a Consolidated Return Be Filed? ... 8-4
Advantages of Filing a Consolidated Tax Return ... 8-4
Disadvantages of Filing a Consolidated Tax Return ... 8-5
Consolidated Taxable Income ... 8-5
Income Included in the Consolidated Tax Return ... 8-7
Affiliated Group Elections ... 8-8
Termination of the Affiliated Group ... 8-8
Computation of the Affiliated Groupus Tax Liability ... 8-9
Regular Tax Liability ... 8-9
Corporate Alternative Minimum Tax Liability ... 8-10
Consolidated Tax Credits ... 8-10
Intercompany Transactions ... 8-11
Property Transactions ... 8-12
Other Intercompany Transactions ... 8-18
Dividends Received By Group Members ... 8-21
Exclusion Procedure ... 8-21
Consolidated Dividends-Received Deduction ... 8-21
Consolidated Charitable Contributions Deduction ... 8-22
Net Operating Losses (NOLs) ... 8-23
Current Year NOLs ... 8-23
Carrybacks and Carryforwards of Consolidated NOLs ... 8-24
Carryback of Consolidated NOL to Separate Return Year ... 8-24
Carryforward of Consolidated NOL to Separate Return Year ... 8-26
Special Loss Limitations ... 8-27
Consolidated Capital Gains and Losses ... 8-32
Section 1231 Gains and Losses ... 8-32
Capital Gains and Losses ... 8-32
Stock Basis Adjustments ... 8-33
Tax Planning Considerations ... 8-35
100% Dividends-Received Deduction Election ... 8-35
Estimated Tax Payments ... 8-35
Compliance and Procedural Considerations ... 8-36
The Basic Election and Return ... 8-36
Parent Corporation as Agent for the Affiliated Group ... 8-37
Liability for Taxes Due ... 8-38
Problem Materials ... 8-38
Discussion Questions ... 8-38
Issue Identification Questions ... 8-40
Problems ... 8-41
Comprehensive Problem ... 8-46
Tax Strategy Problem ... 8-46
Tax Form／Return Preparation Problem ... 8-46
Case Study Problems ... 8-48
Tax Research Problems ... 8-48
CHAPTER 9 PARTNERSHIP FORMATION AND OPERATION ... 9-1
Definition of a Partnership ... 9-2
General and Limited Partnerships ... 9-2
Overview of Taxation of Partnership Income ... 9-4
Partnership Profits and Losses ... 9-4
The Partnerus Basis ... 9-4
Partnership Distributions ... 9-5
Tax Implications of Formation of a Partnership ... 9-5
Contribution of Property ... 9-5
Contribution of Services ... 9-10
Organizational and Syndication Expenditures ... 9-12
Partnership Elections ... 9-12
Partnership Tax Year ... 9-12
Other Partnership Elections ... 9-15
Partnership Reporting of Income ... 9-16
Partnership Taxable Income ... 9-16
Separately Stated Items ... 9-16
Partnership Ordinary Items ... 9-17
Partner Reporting of Income ... 9-17
Partnerus Distributive Share ... 9-17
Special Allocations ... 9-18
Basis for Partnership Interest ... 9-21
Beginning Basis ... 9-21
Effects of Liabilities ... 9-21
Effects of Operations ... 9-23
Special Loss Limitations ... 9-24
At-Risk Loss Limitation ... 9-24
Passive Activity Limitations ... 9-26
Transactions Between a Partner and the Partnership ... 9-26
Sales of Property ... 9-26
Guaranteed Payments ... 9-27
Family Partnerships ... 9-29
Capital Ownership ... 9-29
Donor-Donee Allocations of Income ... 9-30
Tax Planning Considerations ... 9-30
Timing of Loss Recognition ... 9-30
Compliance and Procedural Considerations ... 9-31
Reporting to the IRS and the Partners ... 9-31
Irs Audit Procedures ... 9-32
Problem Materials ... 9-33
Discussion Questions ... 9-33
Issue Identification Questions ... 9-34
Problems ... 9-35
Comprehensive Problem ... 9-43
Tax Strategy Problem ... 9-43
Tax Form／Return Preparation Problem ... 9-44
Case Study Problems ... 9-45
Tax Research Problems ... 9-47
CHAPTER 10 SPECIAL PARTNERSHIP ISSUES ... 10-1
Nonliquidating Distributions ... 10-2
Recognition of Gain ... 10-2
Basis Effects of Distributions ... 10-4
Holding Period and Character of Distributed Property ... 10-7
Nonliquidating Distributions with Sec. 751 ... 10-7
Section 751 Assets Defined ... 10-7
Exchange of Sec. 751 Assets and Other Property ... 10-9
Terminating an Interest in A Partnership ... 10-1
Liquidating Distributions ... 10-1
Sale of a Partnership Interest ... 10-1
Retirement or Death of a Partner ... 10-1
Exchange of a Partnership Interest ... 10-2
Income Recognition and Transfers of a Partnership Interest ... 10-2
Termination of a Partnership ... 10-2
Mergers and Consolidations ... 10-2
Division of a Partnership ... 10-2
Optional Basis Adjustments ... 10-2
Optional Adjustment on Transfers ... 10-2
Optional Adjustment on Distributions ... 10-2
Special Forms of Partnerships ... 10-2
Tax Shelters and Limited Partnerships ... 10-2
Publicly Traded Partnerships ... 10-2
Limited Liability Companies ... 10-2
Limited Liability Partnerships ... 10-2
Electing Large Partnerships ... 10-3
Tax Planning Considerations ... 33
Liquidating Distribution or Sale to Partners ... 10-3
Problem Materials ... 10-3
Discussion Questions ... 10-3
Issue Identification Questions ... 10-3
Problems ... 10-3
Comprehensive Problem ... 10-4
Tax Strategy Problem ... 10-4
Case Study Problems ... 10-4
Tax Research Problems ... 10-4
CHAPTER 11 S CORPORATIONS ... 11-1
Should an S Election Be Made? ... 11-3
Advantages of S Corporation Treatment ... 11-3
Disadvantages of S Corporation Treatment ... 11-3
S Corporation Requirements ... 11-4
Shareholder-Related Requirements ... 11-4
Corporation-Related Requirements ... 11-5
Election of S Corporation Status ... 11-7
Making the Election ... 11-8
Termination of the Election ... 11-9
S Corporation Operations ... 11-1
Taxable Year ... 11-1
Accounting Method Elections ... 11-1
Ordinary Income or Loss and Separately Stated Items ... 11-1
Special S Corporation Taxes ... 11-1
Taxation of the Shareholder ... 11-1
Income Allocation Procedures ... 11-1
Loss and Deduction Pass-Through to Shareholders ... 11-2
Family S Corporations ... 11-2
Basis Adjustments ... 11-2
Basis Adjustments to S Corporation Stock ... 11-2
Basis Adjustments to Shareholder Debt ... 11-2
S Corporation Distributions ... 11-2
Corporations Having No Earnings and Profits ... 11-2
Corporations Having Accumulated Earnings and Profits ... 11-2
Other Rules ... 11-3
Tax Preference Items and Other AMT Adjustments ... 11-3
Transactions Involving Shareholders and Other Related Parties ... 11-3
Fringe Benefits Paid to a Shareholder-employee ... 11-3
Tax Planning Considerations ... 11-3
Election to Allocate Income Based on the S Corporationus Accounting Method ... 11-3
Increasing the Benefits from S Corporation Losses ... 11-3
Passive Income Requirements ... 11-3
Compliance and Procedural Considerations ... 11-3
Making the Election ... 11-3
Filing the Corporate Tax Return ... 11-3
Estimated Tax Payments ... 11-3
Consistency Rules ... 11-3
Sample S Corporation Tax Return ... 11-3
Problem Materials ... 11-3
Discussion Questions ... 11-3
Issue Identification Questions ... 11-4
Problems ... 11-4
Comprehensive Problem ... 11-4
Tax Strategy Problem ... 11-4
Tax Form／Return Preparation Problem ... 11-5
Case Study Problems ... 11-5
Tax Research Problems ... 11-5
CHAPTER 12 THE GIFT TAX ... 12-1
Concept of Transfer Taxes ... 12-2
History and Purpose of Transfer Taxes ... 12-2
The Unified Transfer Tax System ... 12-3
Unified Rate Schedule ... 12-3
Impact of Taxable Gifts on Death Tax Base ... 12-3
Unified Credit ... 12-4
Gift Tax Formula ... 12-4
Determination of Gifts ... 12-4
Exclusions and Deductions ... 12-4
Gift-Splitting Election ... 12-5
Cumulative Nature of Gift Tax ... 12-6
Unified Credit ... 12-6
Transfer Subject to the Gift Tax ... 12-7
Transfers for Inadequate Considerations ... 12-7
Statutory Exemptions from the Gift Tax ... 12-8
Cessation of Donorus Dominion and Control ... 12-1
Valuation of Gifts ... 12-1
Gift Tax Consequences of Certain Transfers ... 12-1
Exclusions ... 12-1
Amount of the Exclusion ... 12-1
Present Interest Requirement ... 12-1
Gift Tax Deductions ... 12-1
Marital Deduction ... 12-1
Charitable Contribution Deduction ... 12-2
The Gift-splitting Election ... 12-2
Computation of the Gift Tax Liability ... 12-2
Effect of Previous Taxable Gifts ... 12-2
Effect of Previous Taxable Gifts ... 12-2
Comprehensive Illustration ... 12-2
Background Data ... 12-2
Calculation of Tax Liability ... 12-2
Basis Considerations for a Lifetime Giving Plan ... 12-2
Property Received By Gift ... 12-6
Property Received At Death ... 12-2
Below-market Loans : Gift and Income Tax Consequences ... 12-2
General Rules ... 12-2
De Minimis Rules ... 12-2
Tax Planning Considerations ... 12-2
Tax-saving Features of Inter Vivos Gifts ... 12-2
Negative Aspects of Gifts ... 12-3
Compliance
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