Prentice Hall's federal taxation . 2002 , corporations, partnerships, estates, and trusts

목차 (Table of Contents)

• 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 Design a Factual Situation Favoring the Taxpayer = 1-6
• The Sources of Tax Law = 1-7
• The L$$\grave e$$gislative Process = 1-7
• The Internal Revenue Code = l-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 = 1-34
• Sample Work Papers and Client Letter = 1-38
• Problem Materials = 1-38
• Discussion Questions = 1-38
• Problems = 1-39
• Comprehensive Problem = 1-42
• Case Study Problem = 1-42
• 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
• Legal Requirements for Forming a Corporation = 2-9
• Tax Considerations in 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 Transferors = 2-16
• Tax Consequences to Transferee Corporation = 2-20
• Assumption of the Transferor's 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
• Capital Contributions By Nonshareholders = 2-30
• Worthlessness of Stock or Debt Obligations = 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
• Case Study Problems = 2-42
• Tax Research Problems = 2-42
• 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 Corporation's 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 Corporation's 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 Form／Return Preparation Problem = 3-46
• Case Study Problems = 3-47
• Tax Research Problems = 3-47
• CHAPTER 4 CORPORATE NONLIQUIDATING DISTRIBUTIONS = 4-1
• Nonliquidating Distributions in General = 4-2
• Earnings and Profits(E&P) = 4-3
• Current Earnings and Profits = 4-3
• Distinction Between Current and Accumulated E&P = 4-6
• 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 Shareholder's 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 Planning Considerations = 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 Problem = 4-45
• Case Study Problems = 4-45
• 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 = 5-5
• Adjustments to Taxable Income = 5-6
• Adjusted Current Earnings(ACE) Adjustment = 5-9
• Minimum Tax Credit = 5-13
• Tax Credits and the AMT = 5-14
• Personal Holding Company Tax = 5-15
• Personal Holding Company Defined = 5-16
• Stock Ownership Requirement = 5-16
• Passive Income Requirement = 5-16
• Determining the PHC Penalty Tax = 5-20
• 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 = 5-25
• Proving a Tax-Avoidance Purpose = 5-25
• Evidence Concerning the Reasonableness of an Earning Accumulation = 5-25
• Determining the Accumulated Earnings Tax Liability = 5-30
• Accumulated Earnings Tax Calculation = 5-33
• Tax Planning Considerations = 5-34
• Special AMT Elections = 5-34
• Eliminating the ACE Adjustment = 5-35
• Avoiding the Personal Holding Company Tax = 5-35
• Avoiding the Accumulated Earnings Tax = 5-36
• Compliance and Procedural Considerations = 5-36
• Alternative Minimum Tax = 5-36
• Personal Holding Company Tax = 5-36
• Accumulated Earnings Tax = 5-37
• Problem Materials = 5-37
• Discussion Questions = 5-37
• Issue Identification Questions = 5-40
• Problems = 5-40
• Comprehensive Problem = 5-46
• Tax Form／Return Preparation Problem = 5-47
• Case Study Problems = 5-47
• Tax Research Problems = 5-48
• 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 Corporation = 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 Obligationsreceived 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's 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 = 6-28
• Case Study Problems = 6-30
• Tax Research Problems = 6-30
• 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 = 7-14
• Tax Consequences of Reorganizations = 7-15
• Target or Transferor Corporation = 7-15
• Acquiring or Transferee Corporation = 7-17
• Shareholders and Security Holders = 7-17
• Acquisitive Reorganizations = 7-21
• Type A Reorganization = 7-21
• Type C Reorganization = 7-27
• Type D Reorganization = 7-29
• Type B Reorganization = 7-30
• Type G Reorganization = 7-34
• Divisive Reorganizations = 7-34
• Divisive Type D Reorganization = 7-34
• Type G Divisive Reorganization = 7-40
• Other Reorganization Transactions = 7-40
• Type E Reorganization = 7-40
• Type F Reorganization = 7-42
• Judicial Restrictions on the Use of Corporate Reorganizations = 7-42
• Continuity of Proprietary Interest = 7-42
• Continuity of Business Enterprise = 7-43
• Business Purpose Requirement = 7-44
• Step Transaction Doctrine = 7-44
• Tax Attributes = 7-45
• Assumption of Tax Attributes = 7-45
• Limitation on Use of Tax Attributes = 7-46
• Tax Planning Considerations = 7-48
• Why Use a Reorganization Instead of a Taxable Transaction? = 7-48
• Avoiding the Reorganization Provisions = 7-49
• Compliance and Procedural Considerations = 7-50
• Section 338 Election = 7-50
• Plan of Reorganization = 7-50
• Party to a Reorganization = 7-50
• Ruling Requests = 7-50
• Problem Materials = 7-51
• Discussion Questions = 7-51
• Issue Identification Questions = 7-52
• Problems = 7-53
• Comprehensive Problem = 7-60
• Case Study Problems = 7-61
• Tax Research Problems = 7-62
• 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 Group's 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
• Tax Form／Return Preparation Problem = 8-46
• Comprehensive Problem = 8-47
• Case Study Problems = 8-47
• Tax Research Problems = 8-47
• 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 Partner's 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 Income = 9-17
• Partner Reporting of Income = 9-17
• Partner's 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 = 9-42
• Tax Form／Return Preparation Problem = 9-42
• Case Study Problems = 9-42
• Tax Research Problems = 9-45
• 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. 75l Assets and Other Property = 10-9
• Terminating an Interest in a Partnership = 10-11
• Liquidating Distributions = 10-12
• Sale of a Partnership Interest = 10-16
• Retirement or Death of a Partner = 10-18
• Exchange of a Partnership Interest = 10-20
• Income Recognition and Transfers of a Partnership Interest = 10-21
• Termination of a Partnership = 10-22
• Mergers and Consolidations = 10-24
• Division of a Partnership = 10-25
• Optional Basis Adjustments = 10-25
• Optional Adjustment on Transfers = 10-26
• Optional Adjustment on Distributions = 10-27
• Special Forms of Partnerships = 10-28
• Tax Shelters and Limited Partnerships = 10-28
• Publicly Traded Partnerships = 10-28
• Limited Liability Companies = 10-29
• Limited Liability Partnerships = 10-29
• Electing Large Partnerships = 10-30
• Tax Planning Considerations = 10-33
• Liquidating Distribution or Sale to Partners = 10-33
• Problem Materials = 10-34
• Discussion Questions = 10-34
• Issue Identification Questions = 10-35
• Problems = 10-36
• Comprehensive Problem = 10-44
• Case Study Problems = 10-45
• Tax Research Problems = 10-46
• 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 = 11-13
• Taxable Year = 11-13
• Accounting Method Elections = 11-14
• Ordinary Income or Loss and Separately Stated Items = 11-14
• Special S Corporation Taxes = 11-15
• Taxation of the Shareholder = 11-19
• Income Allocation Procedures = 11-19
• Loss and Deduction Pass-Through to Shareholders = 11-20
• Family S Corporations = 11-23
• Basis Adjustments = 11-24
• Basis Adjustments to S Corporation Stock = 11-24
• Basis Adjustments to Shareholder Debt = 11-25
• S Corporation Distributions = 11-27
• Corporations Having No Earnings and Profits = 11-27
• Corporations Having Accumulated Earnings and Profits = 11-28
• Other Rules = 11-32
• Tax Preference Items and Other AMT Adjustments = 11-32
• Transactions Involving Shareholders and Other Related Parties = 11-33
• Fringe Benefits Paid to a Shareholder-Employee = 11-33
• Tax Planning Considerations = 11-34
• Election to Allocate Income Based on the S Corporation's Accounting Methods = 11-34
• Increasing the Benefits from S Corporation Losses = 11-35
• Passive Income Requirements = 11-36
• Compliance and Procedural Considerations = 11-37
• Making the Election = 11-37
• Filing the Corporate Tax Return = 11-37
• Estimated Tax Payments = 11-38
• Consistency Rules = 11-39
• Sample S Corporation Tax Return = 11-39
• Problem Materials = 11-39
• Discussion Questions = 11-39
• Issue Identification Questions = 11-41
• Problems = 11-41
• Comprehensive Problems = 11-47
• Tax Form／Return Preparation Problem = 11-49
• Case Study Problems = 11-49
• Tax Research Problems = 11-52
• 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 = 12-3
• Gift Tax Formula = 12-4
• Determination of Gifts = 12-4
• Exclusions and Deductions = 12-4
• Gift-Splitting Election = 12-4
• Cumulative Nature of Gift Tax = 12-5
• Unified Credit = 12-6
• Transfers Subject to the Gift Tax = 12-6
• Transfers for Inadequate Consideration = 12-7
• Statutory Exemptions from the Gift Tax = 12-7
• Cessation of Donor's Dominion and Control = 12-10
• Valuation of Gifts = 12-11
• Gift Tax Consequences of Certain Transfers = 12-13
• Exclusions = 12-15
• Amount of the Exclusion = 12-16
• Present Interest Requirement = 12-16
• Gift Tax Deductions = 12-18
• Marital Deduction = 12-18
• Charitable Contribution Deduction = 12-21
• The Gift-Splitting Election = 12-22
• Computation of the Gift Tax Liability = 12-23
• Effect of Previous Taxable Gifts = 12-23
• Unified Credit Available = 12-24
• Comprehensive Illustration = 12-24
• Background Data = 12-24
• Calculation of Tax Liability = 12-25
• Basis Considerations for a Lifetime Giving Plan = 12-26
• Property Received By Gift = 12-26
• Property Received at Death = 12-26
• Below-Market Loans : Gift and Income Tax Consequences = 12-27
• General Rules = 12-27
• De Minimis Rules = 12-27
• Tax Planning Considerations = 12-28
• Tax-Saving Features of Inter Vivos Gifts = 12-28
• Negative Aspects of Gifts = 12-29
• Compliance and Procedural Considerations = 12-29
• Filing Requirements = 12-29
• Due Date = 12-30
• Gift-Splitting Election = 12-30
• Liability for Tax = 12-30
• Determination of Value = 12-31
• Statute of Limitations = 12-31
• Problem Materials = 12-32
• Discussion Questions = 12-32
• Issue Identification Questions = 12-33
• Problems = 12-33
• Comprehensive Problem = 12-36
• Tax Form／Return Preparation Problems = 12-37
• Case Study Problems = 12-37
• Tax Research Problems = 12-38
• CHAPTER 13 THE ESTATE TAX = 13-1
• Estate Tax Formula = 13-2
• Gross Estate = 13-2
• Deductions = 13-3
• Adjusted Taxable Gifts and Tax Base = 13-3
• Tentative Tax on Estate Tax Base = 13-4
• Reduction for Post-1976 Gift Taxes = 13-4
• Unified Credit = 13-5
• Other Credits = 13-5
• The Gross Estate : Valuation = 13-5
• Date-of-Death Valuation = 13-5
• Alternate Valuation Date = 13-7
• The Gross Estate : Inclusions = 13-8
• Comparison of Gross Estate with Probate Estate = 13-8
• Property in Which the Decedent Had an Interest = 13-9
• Dower or Curtesy Rights = 13-10
• Transferor Provisions = 13-10
• Annuities and Other Retirement Benefits = 13-13
• Jointly Owned Property = 13-14
• General Powers of Appointment = 13-15
• Life Insurance = 13-15
• Consideration Offset = 13-16
• Recipient Spouse's Interest in QTIP Trust = 13-17
• Deductions = 13-18
• Debts and Funeral and Administration Expenses = 13-18
• Losses = 13-19
• Charitable Contribution Deduction = 13-19
• Marital Deduction = 13-20
• Deduction for Certain Interests in Family-Owned Businesses = 13-22
• Computation of Tax Liability = 13-23
• Taxable Estate and Tax Base = 13-23
• Tentative Tax and Reduction for Post-1976 Gift Taxes = 13-23
• Unified Credit = 13-23
• Other Credits = 13-24
• Comprehensive Illustration = 13-25
• Background Data = 13-25
• Calculation of Tax Liability = 13-26
• Liquidity Concerns = 13-28
• Deferral of Payment of Estate Taxes = 13-28
• Stock Redemptions to Pay Death Taxes = 13-29
• Special Use Valuation of Farm Real Property = 13-29
• Generation-Skipping Transfer Tax = 13-30
• Tax Planning Considerations = 13-32
• Use of Inter Vivos Gifts = 13-32
• Use of Exemption Equivalent = 13-32
• What Size Marital Deduction Is Best? = 13-33
• Use of Disclaimers = 13-34
• Role of Life Insurance = 13-34
• Qualifying the Estate for Installment Payments = 13-34
• Where to Deduct Administration Expenses = 13-35
• Compliance and Procedural Considerations = 13-35
• Filing Requirements = 13-35
• Due Date = 13-36
• Valuation = 13-36
• Election of Alternate Valuation Date = 13-36
• Documents to Be Included with Return = 13-36
• Problem Materials = 13-37
• Discussion Questions = 13-37
• Issue Identification Questions = 13-38
• Problems = 13-38
• Comprehensive Problems = 13-42
• Tax Form／Return Preparation Problems = 13-43
• Case Study Problems = 13-44
• Tax Research Problems = 13-45
• CHAPTER 14 INCOME TAXATION OF TRUSTS AND ESTATES = 14-1
• Basic Concepts = 14-2
• Inception of Trusts = 14-2
• Inception of Estates = 14-2
• Reasons for Creating Trusts = 14-3
• Basic Principles Offiduciary Taxation = 14-3
• Principles of Fiduciary Accounting = 14-4
• The Importance of Identifying Income and Principal = 14-4
• Effects of State Law or Terms of Trust Instrument = 14-5
• Principal and Income : The Uniform Act = 14-5
• Categorization of Depreciation = 14-6
• Formula for Taxable Income and Tax Liability = 14-7
• Gross Income = 14-7
• Deductions for Expenses = 14-7
• Distribution Deduction = 14-9
• Personal Exemption = 14-9
• Credits = 14-10
• Distributable Net Income = 14-10
• Significance of DNI = 14-10
• Definition of DNI = 14-11
• Manner of Computing DNI = 14-12
• Determining a Simple Trust's Taxable Income = 14-13
• Allocation of Expenses to Tax-Exempt Income = 14-14
• Determination of DNI and the Distribution Deduction = 14-15
• Tax Treatment for Beneficiary = 14-15
• Short-Cut Approach to Proving Correctness of Taxable Income = 14-16
• Effect of a Net Operating Loss = 14-16
• Effect of a Net Capital Loss = 14-16
• Comprehensive Illustration : Determining a Simple Trust's Taxable Income = 14-17
• Background Data = 14-17
• Trustee's Fee = 14-18
• Distribution Deduction and DNI = 14-18
• Trust's Taxable Income = 14-18
• Categorizing a Beneficiary's Income = 14-18
• Determining Taxable Income for Complex Trusts and Estates = 14-19
• Determination of DNI and the Distribution Deduction = 14-20
• Tax Treatment for Beneficiary = 14-21
• Effect of a Net Operating Loss = 14-24
• Effect of a Net Capital Loss = 14-24
• Comprehensive Illustration : Determining a Complex Trustus Taxable Income = 14-24
• Background Data = 14-24
• Trustee's Fee = 14-25
• Distribution Deduction and DNI = 14-25
• Trust's Taxable Income = 14-26
• Additional Observations = 14-26
• Income in Respect of a Decedent = 14-27
• Definition and Common Examples = 14-27
• Significance of IRD = 14-28
• Grantor Trust Provisions = 14-30
• Purpose and Effect = 14-30
• Revocable Trusts = 14-31
• Clifford Trusts = 14-31
• Post-1986 Reversionary Interest Trusts = 14-31
• Retention of Administrative Powers = 14-32
• Retention of Economic Benefits = 14-32
• Control of Others' Enjoyment = 14-32
• Tax Planning Considerations = 14-34
• Ability to Shift Income = 14-34
• Timing of Distributions = 14-34
• Property Distributions = 14-34
• Choice of Year-End for Estates = 14-35
• Deduction of Administration Expenses = 14-35
• Compliance and Procedural Considerations = 14-35
• Filing Requirements = 14-35
• Due Date for Return and Tax = 14-36
• Documents to Be Furnished to IRS = 14-36
• Sample Simple and Complex Trust Returns = 14-36
• Problem Materials = 14-36
• Discussion Questions = 14-36
• Issue Identification Questions = 14-37
• Problems = 14-38
• Comprehensive Problem = 14-40
• Tax Form／Return Preparation Problems = 14-41
• Case Study Problems = 14-42
• Tax Research Problems = 14-42
• CHAPTER 15 ADMINISTRATIVE PROCEDURES = 15-1
• Role of the Internal Revenue Service = 15-2
• Enforcement and Collection = 15-2
• Interpretation of the Statute = 15-2
• Organization of the IRS = 15-3
• Audits of Tax Returns = 15-4
• Percentage of Returns Examined = 15-4
• Selection of Returns for Audit = 15-4
• Alternatives for a Taxpayer Whose Return Is Audited = 15-6
• 90-Day Letter = 15-8
• Litigation = 15-9
• Requests for Rulings = 15-10
• Information to Be Included in Taxpayer's Request = 15-10
• Will the IRS Rule? = 15-11
• When Rulings Are Desirable = 15-12
• Due Dates = 15-12
• Due Dates for Returns = 15-12
• Extensions = 15-12
• Due Dates for Payment of the Tax = 15-13
• Interest on Tax Not Timely Paid = 15-13
• Failure-to-File and Failure-to-Pay Penalties = 15-15
• Failure to File = 15-16
• Failure to Pay = 15-18
• Estimated Taxes = 15-19
• Payment Requirements = 15-19
• Penalty for Underpaying Estimated Taxes = 15-20
• Exceptions to the Penalty = 15-21
• Other More Severe Penalties = 15-22
• Negligence = 15-22
• Substantial Understatement = 15-23
• Civil Fraud = 15-24
• Criminal Fraud = 15-25
• Statute of Limitations = 15-26
• General Three-Year Rule = 15-26
• Six-Year Rule for Substantial Omissions = 15-26
• When No Return Is Filed = 15-28
• Other Exceptions to Three-Year Rule = 15-28
• Refund Claims = 15-29
• Liability for Tax = 15-29
• Joint Returns = 15-29
• Transferee Liability = 15-31
• Tax Practice Issues = 15-31
• Statutory Provisions Concerning Tax Return Preparers = 15-31
• Rules of Circular 230 = 15-32
• Tax Accounting and Tax Law = 15-33
• Accountant-Client Privilege = 15-34
• Problem Materials = 15-34
• Discussion Questions = 15-34
• Issue Identification Questions = 15-36
• Problems = 15-36
• Comprehensive Problem = 15-39
• Case Study Problem = 15-40
• Tax Research Problems = 15-40
• CHAPTER 16 U.S. TAXATION OF FOREIGN-RELATED TRANSACTIONS = 16-1
• Jurisdiction to Tax = 16-2
• Taxation of U.S. Citizens and Resident Aliens = 16-3
• Foreign Tax Credit = 16-3
• Foreign-Earned Income Exclusion = 16-8
• Taxation of Nonresident Aliens = 16-14
• Definition of Nonresident Alien = 16-14
• Investment Income = 16-15
• Trade or Business Income = 16-16
• Taxation of U.S. Businesses Operating Abroad = 16-18
• Domestic Subsidiary Corporations = 16-19
• Foreign Branches = 16-19
• Foreign Corporations = 16-20
• Controlled Foreign Corporations = 16-23
• Special Foreign Corporation Forms = 16-31
• Foreign Sales Corporations = 16-32
• Domestic International Sales Corporations = 16-35
• Tax Planning Considerations = 16-37
• Deduction Versus Credit for Foreign Taxes = 16-37
• Election to Accrue Foreign Taxes = 16-39
• Special Earned Income Elections = 16-39
• Tax Treaties = 16-39
• Special Resident Alien Elections = 16-40
• Compliance and Procedural Considerations = 16-41
• Reporting the Foreign Tax Credit = 16-41
• Reporting the Earned Income Exclusion = 16-41
• Filing Requirements for Aliens and Foreign Corporations = 16-42
• FSC and DISC Filing Requirements = 16-42
• Problem Materials = 16-42
• Discussion Questions = 16-42
• Issue Identification Questions = 16-43
• Problems = 16-44
• Comprehensive Problem = 16-48
• Tax Form／Return Preparation Problems = 16-49
• Case Study Problems = 16-50
• Tax Research Problems = 16-50
• APPENDICES
• APPENDIX A : Tax Research Working Paper File = A-1
• APPENDIX B : Completed Tax Forms = B-1
• APPENDIX C : MACRS and ACRS Tables = C-1
• APPENDIX D : Glossary = D-1
• APPENDIX E : Statements on Standards for Tax Services = E-1
• APPENDIX F : Comparison of Tax Attributes for C Corporations, Partnerships, and S Corporations = F-1
• APPENDIX G : Credit for State Death Taxes = G-1
• APPENDIX H : Acturial Tables = H-1
• APPENDIX I : Index of Code Sections = I-1
• APPENDIX J : Index of Treasury Regulations = J-1
• APPENDIX K : Index of Government Promulgations = K-1
• APPENDIX L : Index of Court Cases = L-1
• APPENDIX M : Subject Index = M-1