This first edition of Federal Taxation of Corporations and Corporate Transactions provides a comprehensive examination of tax principles with a unique practice-oriented approach to help students become practice ready with skills that they have developed in a setting that reflects practice in the real world. The casebook introduces students not only to transactional tax practice and the federal tax penalty regime, but also to the rules of professional ethics and the specific rules that govern professionals who practice tax law. It features an array of Deal Downloads that breathe life into complex material, presenting high-profile transactions involving Amazon, Apple, Ford and others. This first edition will have a separately sold Client File supplement, which provides memoranda that require students to analyze the Deal Download transactions and to employ them as precedents to structure acquisitions, investments, and distributions for a hypothetical client. Key Benefits: Client files that are designed to help students learn the law in a practice-like setting. Extensive commentary about tax principles and cites to statutes, cases, regulations, and rulings that the students must study to fully learn the material. Chapter 9, where students will learn about the transaction that heralded the return of Steve Jobs to Apple in the 1990s and paved the way for the company’s subsequent dominant run. An examination of issues posed by classic cases, by focusing on the language of the underlying deal documents, and by learning how to solve clients’ problems before they are set in stone.

This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.

The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. This well-regarded textbook continues its fundamental approach of clear explanations, pervasive examples, and comprehensive problem sets throughout. Utilizing a problems-based approach, Federal Income Taxation of Corporations and Partnerships, Sixth Edition by Howard E. Abrams and Don Leatherman covers taxation of the three major categories of business entities: Corporations, S Corporations, and Partnerships. New to the Sixth Edition: The text has been updated to reflect the 2017 Tax Cut and Jobs Act. The chapter on taxable acquisitions has been modified to be more complete yet easier to understand. The chapter on tax-free acquisitive reorganizations has been modified to include more problems as well as a section on the substance-over-form doctrine. The Partnership Taxation presentation has been updated to include integration with new bonus depreciation rules, modernization of section 751(b), elimination of technical terminations, and expansion of substantial built-in loss. Professors and students will benefit from: Clarification of the intricacies of the taxation of business enterprises Problems and examples in addition to cases and notes to cover all aspects of the subject Illustrations of typical commercial transactions An emphasis on major themes of policy and practice A book that is flexible enough to be used in two-, three-, or four-credit courses Stand-alone coverage of C corporations, S corporations, and partnerships

The six papers in this vohune represent state-of-the-art empirical and conceptual research on various aspects of the taxation of multinational corporations. They were commissioned for and presented at a conference organized by Price Waterhouse LLP on behalf of the International Tax Policy Forum, held in Washington, DC in March, 1994. The ftrst four papers were originally published in the May, 1995 issue of International Tax and Public Finance. The Slemrod paper appeared in the Policy Watch Section of the November, 1995 issue of that journal. The foregoing papers were subject to the normal refereeing procedures of the journal, and the summaries that follow are drawn from there. The Leamer paper has not been previously published. Altshuler and Mintz examine one aspect of the 1986 u. s. Tax Reform Act --the change in the rules for the allocation of interest expense between domestic-(U. S. ) and foreign-source income. In the absence of rules, a parent with excess credits could reduce U. S. tax liability by allocating interest expense toward itself; thus reducing its taxable domestic income without any compensating increase in either the U. S. tax due on foreign-source income or the foreign tax due (which is independent of U. S. rules).

The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the merits and limitations of allocation methods for attributing income to different jurisdictions according to formulas measuring business activity. Such methods are being used as part of transfer pricing regimes and are likely to be enhanced over time. Whatever international arrangements develop in the future, there is a role for new institutions to improve cooperative discussions among governments.