Estate And Gift Taxation

Hellwig, Brant J.

Danforth, Robert T.

Durham, NC : Carolina Academic Press

The Tenth Edition of this widely used casebook continues its long tradition of teaching the “fundamentals” of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the Tenth Edition include: 
<ul>
<li>Coverage of all significant developments since the last edition, including the impact on choice of business entity of the now permanent higher marginal individual tax rates and the 3.8% tax on net investment income tax; final regulations on noncompensatory options and partnership allocations where interests change during the year; and new proposed regulations on partnership liabilities, § 751(b) disproportionate distributions, and disguised payments for services as applied to investment management fee waivers and similar strategies to convert ordinary income to capital gain.</li>
<li>Reorganized and integrated materials related to compensating the service partner in a new and fully updated self-standing chapter.</li>
<li>Shorter separate chapters on partnership allocations, allocation of partnership liabilities, income-shifting safeguards, partner-partnership property transactions, liquidating distributions, and partnership terminations and mergers.</li>
<li>Updated discussion of tax policy issues affecting partnerships, including prospects and options for business tax reform and the continuing debate on taxing “carried interests.”</li>
<li>A new case (Canal Corporation v. Commissioner) illustrating a successful IRS attack on the debt-financed distribution gain deferral strategy.</li>
<li>S corporation developments, including temporary Code provisions made permanent; final regulations on the basis of indebtedness of S corporations to their shareholders; and expanded coverage of employment tax issues affecting S corporation owners who are active in the business.</li>
</ul>

Fundamentals of Partnership Taxation (University Casebook Series)

LATHROPE, DANIEL J.

Schwarz,Stephen

Tax Law

Foundation Press

Offered as an alternative to the authors’ widely used separate texts on corporate and partnership tax, the Sixth Edition of this comprehensive casebook continues its tradition of providing an integrated approach to teaching the “fundamentals” of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, selective discussion of tax policy issues, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the Sixth Edition include: 
<ul>
<li>Coverage of all significant C corporation and partnership developments since the last edition, including the impact of the now permanent higher marginal individual tax rates and the 3.8% net investment income tax; new legislation blocking tax-free spin-offs of REITs; final regulations on § 336(e) elections, Type F reorganizations, noncompensatory options, and partnership allocations where interests change during the year; and new proposed regulations on § 355 corporate divisions, partnership liabilities, § 751(b) disproportionate distributions, and disguised payments for services as applied to investment management fee waivers and similar strategies to convert ordinary income to capital gain.</li>
<li>Updated and reorganized discussion of the continuity of proprietary interest doctrine in tax-free reorganizations.</li>
<li>Integrated materials related to compensating the service partner in a new and fully updated self-standing chapter.</li>
<li>Shorter separate chapters on partnership allocations, allocation of partnership liabilities, income-shifting safeguards, partner-partnership property transactions, liquidating distributions, and partnership terminations and mergers.</li>
<li>A new case (Canal Corporation v. Commissioner) illustrating a successful IRS attack on the debt-financed distribution gain deferral strategy.</li>
<li>Updated discussion of business enterprise tax policy issues, including a new overview of issues affecting U.S. multinational corporations, the latest prospects and options for comprehensive tax reform, and the ongoing debate on taxing partnership “carried interests.”</li>
<li>A completely updated chapter on S corporations, incorporating temporary Code provisions made permanent and final regulations on the basis of indebtedness of S corporations to their shareholders, and expanded coverage of employment tax issues affecting S corporation owners who are active in the business.</li>
</ul>

Fundamentals of Business Enterprise Taxation (University Casebook Series)

This comprehensive and clearly written text is designed to help students recognize and understand the basic principles and issues covered in law school courses in partnership or pass-through entity taxation at both the J.D. and LL.M. levels. It explains all the fundamental concepts and transactions affecting partnerships, limited liability companies, and S corporations and includes numerous illustrative examples, self-test questions with answers, and sample exam questions.

Black Letter Outline on Partnership Taxation (Black Letter Outlines)

West Academic Publishing

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