Federal Income Taxation of Partners and Partnerships in a Nutshell

Author: Karen Burke

Publisher: West Academic Publishing

ISBN: 9781634607124

Category:

Page: 463

View: 6895

This book provides a concise overview of federal partnership taxation. It covers partnership formation, including contributions of property and admission of service partners, allocation of income and loss, tax accounting, and sharing of recourse and nonrecourse liabilities. Building on this foundation, the book also addresses advanced topics, including transactions between partners and partnerships, sales of partnership interests, distributions of property, optional and mandatory basis adjustments, and planning for retirement or death of a partner. Numerous concrete examples illustrate the tax treatment of specific transactions, allowing students to grasp the principles of partnership taxation in a problem-oriented course. The revised fifth edition reflects developments through September 2016, including proposed rules relating to compensatory profits interests and fee waivers, contributed built-in loss property, sharing of partnership liabilities and disguised sales, basis adjustments under �� 734(b), 743(b) and 755, and � 751(b) distributions.

Partnership Taxation

Author: George K. Yin,Karen C. Burke

Publisher: Wolters Kluwer Law & Business

ISBN: 1454879599

Category: Law

Page: 456

View: 6427

Partnership Taxation, Third Edition is a concise, tightly-edited casebook, written by Distinguished Professor of Law and Taxation George K. Yin, and Richard B. Stephens Eminent Scholar in Taxation at the University of Florida Levin College of Law Karen C. Burke, that focuses on core principles and policies so that students can learn the major patterns and themes of partnership taxation. Key Features of the New Edition: • Economic substance doctrine guidance and partnership audit rules enacted in 2015 • Proposed regulations implementing section 704(c)(1)(C) for contributed built-in loss property • Final regulations under section 706 when partners’ interests vary during the year • Proposed regulations under sections 707 and 752 on disguised sales, fee waivers, and sharing of partnership liabilities • Proposed regulations under section 751(b) addressing shifts in ordinary income

Mastering Partnership Taxation

Author: Stuart Lazar

Publisher: N.A

ISBN: 9781594608650

Category: Law

Page: 321

View: 7892

Mastering Partnership Taxation guides students through the complex tax rules affecting partnerships and their partners. The discussion of each topic is designed to provide a basic understanding of the rules of Subchapter K of the Internal Revenue Code. It is specifically designed for students taking a class in partnership tax. Each chapter begins with a roadmap to introduce the material to be presented and ends with checkpoints that summarize the information covered.Mastering Partnership Taxation takes students through the entire life cycle of a partnership, beginning with partnership formations and ending with partnership liquidations and partnership mergers. The topics covered include: the entity v. aggregate theories of taxation; the “check the box” regulations; a comparison of partnerships to corporations and S corporations; the consequences of partner contributions to a partnership; transfers of compensatory partnership interests; an introduction to partnership accounting; an introduction to partnership debt; allocations of partnership income; partnership distributions; transactions between partnerships and their partners; and dispositions of partnership interests.This book is part of the Carolina Academic Press Mastering Series edited by Russell L. Weaver, University of Louisville School of Law.

International Taxation in a Nutshell

Author: Richard Doernberg

Publisher: West Academic Publishing

ISBN: 9781628105551

Category:

Page: 676

View: 1543

This nutshell not only addresses the fundamentals of U.S. international taxation, but it also offers insight into tax planning considerations. Both the U.S. activities of foreign taxpayers, as well as the foreign activities of U.S. taxpayers are explored. In the truly global economy in which we live, it is crucial for those involved in business and investment activities to understand the tax consequences that impact cross-border flows. Building on both academic and private sector careers, the author has used his experience to distill the complexities of real-world tax considerations into a clearly written, straight-forward presentation of the key international tax concepts, including the most recent developments.

Federal Income Taxation of Corporations and Stockholders in a Nutshell

Author: Karen C. Burke

Publisher: N.A

ISBN: 9780314288226

Category: Law

Page: 480

View: 2461

This edition has been completely revised to reflect developments in the Code, regulations, and case law through October 2013. The text focuses on the corporation as a taxable entity and tracks the corporate life cycle from incorporation through complete liquidation. It includes discussion on nonliquidating distributions, redemptions, and stock dividends. It also addresses advanced problems in corporate taxation, such as taxable acquisitions, tax-free reorganizations and corporate divisions, and carryover of corporate tax attributes.

The Logic of Subchapter K, a Conceptual Guide to the Taxation of Partnerships

Author: Laura Cunningham,Noel Cunningham

Publisher: West Academic Publishing

ISBN: 9781634604727

Category:

Page: 361

View: 2188

This course book is designed to guide students through the conceptual framework of subchapter K. The material avoids neither the hard questions nor the conceptual difficulties, leaving students with a firm understanding of partnership taxation. Each chapter begins with a basic explanation of the relevant provisions and the roles that they play in the overall structure of subchapter K. It includes an increasingly detailed discussion of the specific rules, including multiple illustrative examples. Each chapter builds on the earlier chapters, leading the student through subchapter K. It is appropriate for J.D. or graduate-level law school courses on partnership taxation.

Taxation of S Corporations in a Nutshell

Author: Douglas Kahn,Terrence Perris

Publisher: West Academic Publishing

ISBN: 9781683282204

Category:

Page: 251

View: 3032

The Subchapter S rules are complex. This book describes the basic rules that apply to S corporations and their shareholders with sufficient detail to alert the reader to potential pitfalls. The topics covered include: (1) the qualification requirements for a Subchapter S election, (2) the allocation of tax items among the shareholders, (3) the effect of those allocations on a shareholder's basis in stock and debt, (4) the limitations on the deduction of pass through items, (5) the treatment of corporate distributions, (6) the voluntary and involuntary termination of Subchapter S status, (7) the treatment of the year in which a Subchapter S election is terminated, (8) the limited availability of certain Subchapter S provisions after a Subchapter S election is terminated, and (9) the taxation of an S corporation's passive investment income and built-in gains. The discussion of these issues is supplemented by numerous examples.

Exam Pro on Partnership Taxation

Author: Robert Wootton

Publisher: West Academic Publishing

ISBN: 9781634594943

Category:

Page: 563

View: 2477

Finally, a partnership tax study guide with questions and answers. Written by an acclaimed teacher at Northwestern University, the Exam Pro on Partnership Taxation is designed to help JD and LLM students from the first day of class through the final exam. It begins with over 50 short lectures on topics in partnership tax ranging from basic to advanced, illustrated by over 250 study problems, each with a complete explanation of the right (and wrong) answers. Several of these lectures focus on the basic accounting concepts that are essential to understanding partnership tax, to give students with no prior accounting background the tools they need to succeed in this subject. The book includes nine sample exams that, like the lectures, increase in difficulty from basic to advanced, labeled so that students can pick the exams that are right for them and the course they are taking. Full answers to each of the exam questions are provided, with cross-references to the lectures and the study questions. Robert R. Wootton is a Professor of Practice at Northwestern Pritzker School of Law who practiced in big law for 25 years and was the Tax Legislative Counsel of the U.S. Treasury Department. The students in Northwestern Pritzkerâe(tm)s LLM Tax Program have named him its outstanding tax professor seven times.

The Law of Tax-exempt Organizations in a Nutshell

Author: Scott A. Taylor

Publisher: West Academic Publishing

ISBN: 9780314262349

Category: Law

Page: 319

View: 6177

This nutshell provides a valuable introduction and foundation for those students taking classes dealing with the law of nonprofit organizations and the tax treatment of them. Special treatment is provided on charitable giving, fundraising, unrelated business income, and private foundations. Because of its focus on the law, this nutshell will be a valuable introduction to nonprofit professionals needing a concise overview of the legal problems that nonprofit organizations routinely face.

Black Letter Outline on Partnership Taxation

Author: Stephen Schwarz,Brant Hellwig,Daniel Lathrope

Publisher: West Academic Publishing

ISBN: 9781634602921

Category:

Page: 283

View: 3506

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.

Tax Procedure and Tax Fraud in a Nutshell

Author: Camilla E. Watson

Publisher: West Group

ISBN: 9780314146465

Category: Law

Page: 431

View: 4738

Reliable source on tax procedure and tax fraud helps bridge the gap between understanding "substantive" code provisions and preparing to represent a taxpayer in an Internal Revenue Service (IRS) dispute. Coverage includes IRS and treasury rulemaking; confidentiality and disclosure; audits and administrative appeals; statute of limitations; litigation considerations; penalties and collection process; liability; investigation; and tax crimes.

Drafting Delaware Limited Liability Company Agreements

Forms and Practice Manual

Author: John M. Cunningham,Vernon R. Proctor

Publisher: Aspen Publishers Online

ISBN: 9780735582682

Category: Law

Page: 1048

View: 5396

Drafting Delaware LLC Agreements: Forms and Practice Manual provides a comprehensive and sophisticated analysis of the Delaware Limited Liability Company Act from an entity formation viewpoint and sets forth extensive practical guidelines for lawyers planning, negotiating and drafting Delaware LLC agreements. Among other features: The book exhaustively identifies the definitional, mandatory, default and permissive provisions critical in forming Delaware LLCs, and it addresses in detail the more important of these provisions. It contains detailed criteria and practical examples for use in choosing among Delaware LLCs and other types of Delaware entities, including limited partnerships and corporations, in business entity formations ("non-tax choice of entity"). To the authors' knowledge, it provides the most complete analysis of the series LLC provisions of the Delaware Act currently available in LLC literature. It provides in digital form model LLC agreements that address all of the various ownership structures, management structures and tax structures that Delaware LLC formation clients may need--a total of nine agreements for single-member LLCs and 33 for multi-member LLCs. Finally, the book contains plain-English explanations for lawyers who are not tax specialists concerning all principal federal and state tax issues likely to be important to Delaware entity formation clients. A CD containing customizable agreements, for ease of use, along with the full text of the Delaware Limited Liability Company Act is included with your purchase! SPECIAL OFFER... Get the latest monthly edition of Drafting Delaware LLC Agreements: Forms and Practice Manual E-Newsletter. Download your FREE E-Newsletter NOW! The co-authors of the book and E-Newsletter are John M. Cunningham, the author of Drafting Limited Liability Company Operating Agreements (Aspen Publishers), the leading generic (i.e., non-state specific) LLC form book and practice manual; and Vernon R. Proctor, a partner and co-founder of Proctor Heyman LLP, a Wilmington, Delaware business litigation law firm. Mr. Proctor is a member of the Delaware State Bar Association committee that annually updates the Delaware LLC Act and the other Delaware "alternative entity" statutes.

Accounting and Finance for Lawyers in a Nutshell

Author: Charles Meyer

Publisher: West Academic Publishing

ISBN: 9781634608510

Category:

Page: 561

View: 1580

This product provides a well-rounded summary of the relevant accounting areas from basic financial statements to complex earnings-per-share ratios and corporate finance and valuation. Learn how to recognize revenue, expenses, assets, and liabilities. It reviews accounting principles for many different areas, including acquisitions, investments, long-term debt, leases, stocks, and partnerships. It also discusses recent developments such as adoption of new requirements to place most operating leases on the lessee's balance sheet, a new principles based approach to accounting for revenue, refinements in the accounting for stock options, and revised rules for applying the lower of cost or market rule to inventory.

Taxpayer's Comprehensive Guide to LLCs and S Corps

Author: Jason Watson

Publisher: Watson CPA Group

ISBN: 0990763293

Category: Business & Economics

Page: 136

View: 5301

How can I avoid self-employment taxes? This simple question was the inspiration for creating an article describing the benefits of an S Corporation. That original article, which was about four pages long, quickly became a series of KnowledgeBase articles on the Watson CPA Group website. The articles touched on basic topics such as how to elect S Corp status, payroll, reasonable salary determination, retirement planning, health care, fringe benefits and liability protection. Those broad topics demanded much more information, both horizontally by spanning into more related issues, and vertically by digging deeper into the granular yet riveting levels of the tax code. The articles were grouped and relabeled as the Taxpayer’s Comprehensive Guide to LLCs and S Corps which grew to 39 pages in its first edition. Time marched on, and more information was added to the first edition such as expanded retirement planning concerns, health care options after the Affordable Care Act and business valuations including exit strategies. Boom, we now had our second edition at over 100 pages. At that point it was suggested by some clients and colleagues to convert the PDF into an eBook as well as paperback. So here we are.. Each week we receive several phone calls and emails from small business owners across the country who have read our Taxpayer’s Comprehensive Guide to LLCs and S Corps and praised the wealth of information. Regardless of your current situation, whether you are considering starting your own business or entertaining a contracting gig, or you are an experienced business owner, the contents of this book are for you. This book will show you how to reduce your self-employment taxes through an S Corporation election and how to use your corporation to your retirement and fringe benefit advantage. You will also learn the operational considerations of an S Corp plus the 185 reasons you should NOT elect S Corp status. Want to buy or sell a business? That’s in here too. This book is written with the general taxpayer in mind. Too many resources simply regurgitate complex tax code without explanation. While in some cases tax code and court opinions are duplicated verbatim because of the precise words, this book strives to explain many technical concepts in layperson terms with some added humor and opinions. We believe you will find this book educational as well as amusing.

Federal Income Taxation of Estates, Trusts, and Beneficiaries in a Nutshell

Author: Grayson M. P. McCouch

Publisher: N.A

ISBN: 9781634603096

Category: Decedents' estates

Page: 435

View: 364

This comprehensive guide can serve either as a course supplement or as a refresher for members of the bar. Expert commentary summarizes the law and offers critical perspectives on the federal income taxation of estates, trusts, and beneficiaries, including the decedent's final income tax return; classification of estates and trusts; income in respect of a decedent; distributable net income; simple and complex trusts; distributions; grantor trusts; charitable trusts; and foreign trusts. Additional chapters cover basic income, gift and estate tax concepts, accumulation distributions, and specially treated trusts.

Federal Income Tax

Code and Regulations--Selected Sections as of June 1, 2008

Author: Martin B. Dickinson

Publisher: CCH

ISBN: 9780808018636

Category: Business & Economics

Page: 2027

View: 7256

CCH's Federal Income Tax: Code and Regulations--Selected Sections provides a selection of the Internal Revenue Code and Treasury Regulations pertaining to income tax. This popular volume reflects the collective judgment of seven distinguished tax teachers and provides an effective mix of official materials for individual and business undergraduate and graduate tax courses offered in law and business schools. It provides in one volume, the provisions most commonly addressed in income tax courses The book's highly readable 7-1/2" x 10" oversized page format make it easier to read for both professor and student. The book is an attractive alternative to the full text of the multi-volume Internal Revenue Code and Income Tax Regulations.

Federal Income Taxation

Author: MARVIN A.. ZELENAK CHIRELSTEIN (LAWRENCE.),Lawrence Zelenak

Publisher: Foundation Press

ISBN: 9781640208247

Category:

Page: 545

View: 1075

This highly-acclaimed text explains the conceptual basis of federal income taxation. It is designed to help students quickly pull together the entire subject for end-of-semester review and provide perspective about where a topic fits within the federal income tax scheme. While focusing on the present income tax, the text provides an explanation of the often-discussed consumption tax and contrasts the two taxes in a note at the end of the volume. The new edition reflects developments since the thirteenth edition, including many changes made by the Tax Cuts and Jobs Act of 2017--the most significant federal tax legislation in more than thirty years.

Fundamentals of Partnership Taxation

Cases and Materials

Author: Stephen A. Lind

Publisher: N.A

ISBN: N.A

Category: Law

Page: 432

View: 7514

The Fifth Edition of Fundamentals of Partnership Taxation integrates all significant new developments, making a particular effort to adhere to their highly successful concept of providing "fundamentals" coverage for one of the most demanding courses in the law school curriculum.

Problems and Solutions in Partnership Tax

Author: Joni Larson

Publisher: N.A

ISBN: 9781611634914

Category: Law

Page: 293

View: 8925

The theory behind the ''flow-through'' tax treatment given partnerships is relatively straight forward -- the partnership files an information return (paying no tax) and all partnership items are allocated among and reported by the partners on their individual income tax returns (and they pay the associated tax). However, the rules that govern how the items are allocated are complex, layered, and intricate. In addition, there are related rules, such as those for the determination of basis, how to tax sales of partnership interests, and how to treat the distribution of cash or property from the partnership. Often, the best way to understand how complex rules work and the results they are intended to bring about are seen best through examples of application of the rules. Problems and Solutions in Partnership Tax does just that; it provides numerous examples of how the rules for partnerships are applied. It begins with the most basic, such as the rules governing the contribution of property to a partnership, selection of the taxable year, and computation of partnership taxable income. It also covers the more complex rules, such as those governing special allocations of recourse deductions, allocation of recourse liabilities, allocation of nonrecourse deductions, allocation of nonrecourse liabilities, and disproportionate distributions. Throughout, the examples are keyed to the partnership balance sheet, showing the effect the applicable rule has on the relationship of the partners to the partnership and the partners to each other. This book is a great resource for anyone practicing partnership taxation.