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West Federal Taxation : Comprehensive Volume

by
Edition:
29th
ISBN13:

9780324304954

ISBN10:
0324304951
Format:
Paperback
Pub. Date:
4/20/2005
Publisher(s):
South-Western College/West
List Price: $223.33
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Summary

Combining the number one Individual tax text with the number one Corporations text, WEST FEDERAL TAXATION: COMPREHENSIVE VOLUME, 2006 EDITION is a true winner. An edited version of the first two WFT textbooks, this book offers a thorough and balanced treatment of relevant tax Code and regulations as applied to individuals and corporations. Ideal for undergraduate or graduate levels, this text works for either a one-semester course in which an instructor wants to integrate coverage of individual and corporate taxation, or for a two-semester sequence in which the use of only one book is desired.

Table of Contents

Preface iii
An Introduction to Taxation and Understanding the Federal Tax Law
1(1)
History of U.S. Taxation
3(1)
Early Periods
3(1)
Revenue Acts
3(1)
Historical Trends
4(1)
Criteria Used in the Selection of a Tax Structure
4(1)
Tax in the News: Adam Smith Stopped Too Soon
5(1)
The Tax Structure
5(1)
Tax Base
5(1)
Tax Rates
6(1)
Incidence of Taxation
6(1)
Major Types of Taxes
6(13)
Property Taxes
6(1)
Tax in the News: College Expansion May Cause Property Tax Erosion
7(2)
Transaction Taxes
9(1)
Ethical Considerations: Making Good Use of Out-of-State Relatives
10(1)
Death Taxes
11(1)
Gift Taxes
12(2)
Income Taxes
14(1)
Tax in the News: Using the Income Tax Return As a ``Use Tax'' Reminder
15(1)
Employment Taxes
16(1)
Other U.S. Taxes
17(1)
Proposed U.S. Taxes
17(2)
Tax Administration
19(5)
Internal Revenue Service
19(1)
The Audit Process
19(2)
Tax in the News: The IRS Gets Tough with Taxpayers Who Refuse to Pay
21(1)
Statute of Limitations
21(1)
Interest and Penalties
22(1)
Tax Practice
23(1)
Ethical Considerations: Do You Sign or Not?
23(1)
Understanding the Federal Tax Law
24(10)
Revenue Needs
24(1)
Global Tax Issues: Outsourcing of Tax Return Preparation
25(1)
Economic Considerations
25(2)
Social Considerations
27(1)
Equity Considerations
27(3)
Political Considerations
30(1)
Influence of the Internal Revenue Service
31(1)
Ethical Considerations: Deducting Uncollected Charges for Services Rendered
31(1)
Influence of the Courts
32(1)
Summary
33(1)
Problem Materials
34
Working with the Tax Law
1(1)
Tax Sources
2(19)
Statutory Sources of the Tax Law
2(1)
Tax in the News: Tax Freedom Day?
3(3)
Tax in the News: Those Disappearing Dependents
6(1)
Global Tax Issues: Tax Treaties
7(1)
Ethical Considerations: The President and the IRS
8(1)
Administrative Sources of the Tax Law
8(4)
Judicial Sources of the Tax Law
12(2)
Tax in the News: Changing the Face of Russia
14(7)
Working with the Tax Law---Tax Research
21(7)
Identifying the Problem
22(1)
Refining the Problem
22(1)
Locating the Appropriate Tax Law Sources
23(2)
Assessing the Validity of the Tax Law Sources
25(2)
Arriving at the Solution or at Alternative Solutions
27(1)
Communicating Tax Research
28(1)
Working with the Tax Law---Tax Planning
28(10)
Nontax Considerations
30(1)
Tax Evasion and Tax Avoidance
31(1)
Ethical Considerations: Tax Avoidance: Good or Bad?
31(1)
Follow-up Procedures
31(1)
Tax in the News: The Disappearing Taxpayers
32(1)
Tax Planning---A Practical Application
32(1)
Electronic Tax Research
33(2)
Global Tax Issues: Data Warehousing Reduces Global Taxes
35(3)
Problem Materials
38
Tax Determination; Personal and Dependency Exemptions; An Overview of Property Transactions
1(1)
Tax Formula
3(7)
Components of the Tax Formula
3(2)
Global Tax Issues: Citizenship Is Not Tax-Free
5(3)
Application of the Tax Formula
8(1)
Individuals Not Eligible for the Standard Deduction
9(1)
Special Limitations for Individuals Who Can Be Claimed as Dependents
9(1)
Personal and Dependency Exemptions
10(9)
Personal Exemptions
10(1)
Dependency Exemptions---Prior to 2005
11(1)
Ethical Considerations: Discovering Lost Dependency Exemptions
12(2)
Ethical Considerations: A Change of Residence Can Be Rewarding
14(1)
Dependency Exemptions---After 2004
15(2)
Phaseout of Exemptions
17(1)
Tax in the News: How to Subtly Pluck the Chicken
18(1)
Child Tax Credit
18(1)
Tax Determination
19(5)
Tax Table Method
19(1)
Tax Rate Schedule Method
19(1)
Computation of Net Taxes Payable or Refund Due
20(1)
Tax in the News: Tax Rate Trauma
21(1)
Unearned Income of Children Under Age 14 Taxed at Parents' Rate
22(2)
Filing Considerations
24(7)
Filing Requirements
24(3)
Tax in the News: Special Rules for Certain Military Personnel
27(1)
Filing Status
27(1)
Tax in the News: ``Charge It''---Convenient But Not Cheap!
28(1)
Global Tax Issues: Filing a Joint Return
29(2)
Ethical Considerations: The 'Hidden Benefits of Taking Care of a Relative
31(1)
Gains and Losses from Property Transactions---In General
31(1)
Gains and Losses from Property Transactions---Capital Gains and Losses
32(2)
Definition of a Capital Asset
32(1)
Taxation of Net Capital Gain
33(1)
Determination of Net Capital Gain
33(1)
Treatment of Net Capital Loss
34(1)
Tax Planning Considerations
34(3)
Taking Advantage of Tax Rate Differentials
34(1)
Income of Minor Children
35(1)
Dependency Exemptions
35(2)
Ethical Considerations: Nondependents Can Provide Tax Benefits
37(1)
Problem Materials
37
Gross Income: Concepts and Inclusions
1(1)
Global Tax Issues: From ``All Sources'' Is a Broad Definition
3(1)
Gross Income---What Is It?
3(3)
Definition
3(1)
Economic and Accounting Concepts
3(2)
Tax in the News: Your Silent Gambling Partner: If You Win!
5(1)
Comparison of the Accounting and Tax Concepts of Income
5(1)
Form of Receipt
6(1)
Recovery of Capital Doctrine
6(1)
Year of Inclusion
6(8)
Taxable Year
6(1)
Accounting Methods
7(2)
Exceptions Applicable to Cash Basis Taxpayers
9(1)
Ethical Considerations: Choosing When to File Insurance Claims
10(2)
Global Tax Issues: Tax Credit Neutralizes Foreign Income Taxes
12(1)
Exceptions Applicable to Accrual Basis Taxpayers
12(2)
Income Sources
14(6)
Personal Services
14(1)
Income from Property
14(3)
Ethical Considerations: Enhancing Lottery Winnings
17(1)
Income Received by an Agent
17(1)
Income from Partnerships, S Corporations, Trusts, and Estates
17(1)
Income in Community Property States
18(2)
Items Specifically Included in Gross Income
20(15)
Alimony and Separate Maintenance Payments
20(3)
Imputed Interest on Below-Market Loans
23(2)
Ethical Considerations: A Concealed Loan
25(1)
Tax in the News: Loans to Executives Prohibited
26(2)
Income from Annuities
28(3)
Prizes and Awards
31(1)
Group Term Life Insurance
32(1)
Unemployment Compensation
33(1)
Social Security Benefits
33(1)
Tax in the News: A Taxpayer Learns about the ``Quirky'' Social Security Benefits Taxation Formula
34(1)
Tax Planning Considerations
35(4)
Nontaxable Economic Benefits
35(1)
Tax Deferral
35(1)
Shifting Income to Relatives
36(1)
Accounting for Community Property
37(1)
Alimony
38(1)
Problem Materials
39
Gross Income: Exclusions
1(1)
Items Specifically Excluded from Gross income
2(2)
Statutory Authority
4(1)
Gifts and Inheritances
4(2)
General
4(1)
Tax in the News: Begging as a Tax-Disfavored Occupation
5(1)
Gifts to Employees
5(1)
Employee Death Benefits
5(1)
Tax in the News: Frequent-Flier Miles Will Not Be Taxed
6(1)
Life Insurance Proceeds
6(3)
General Rule
6(1)
Accelerated Death Benefits
7(1)
Ethical Considerations: Should the Terminally Ill Pay Social Security Taxes?
8(1)
Transfer for Valuable Consideration
8(1)
Scholarships
9(2)
General Information
9(1)
Timing Issues
10(1)
Disguised Compensation
10(1)
Qualified Tuition Reduction Plans
10(1)
Compensation for Injuries and Sickness
11(2)
Damages
11(1)
Workers' Compensation
12(1)
Accident and Health Insurance Benefits
13(1)
Tax in the News: Abandoning Parent Gets an ``Undeserved'' Benefit Tax-Free
13(1)
Employer-Sponsored Accident and Health Plans
13(3)
Tax in the News: Employees Pay Tax on Disability Premiums to Attain Nontaxable Disability Pay
14(1)
Global Tax Issues: When Jobs Leave the Country, So Do the Health Insurance Benefits
14(1)
Tax in the News: The Staggering Cost of Employee Health Insurance
15(1)
Medical Reimbursement Plans
15(1)
Long-Term Care Insurance Benefits
15(1)
Meals and Lodging
16(3)
Furnished for the Convenience of the Employer
16(2)
Other Housing Exclusions
18(1)
Other Employee Fringe Benefits
19(7)
Specific Benefits
19(1)
Cafeteria Plans
19(1)
Flexible Spending Plans
20(1)
General Classes of Excluded Benefits
20(6)
Taxable Fringe Benefits
26(1)
Foreign Earned Income
26(2)
Ethical Considerations: Who Should Benefit from the Foreign Earned Income Exclusion?
27(1)
Global Tax Issues: U.S. Taxpayers Abroad Are Gone but Not Forgotten
28(1)
Interest on Certain State and Local Government Obligations
28(1)
Dividends
29(1)
General Information
29(1)
Stock Dividends
29(1)
Educational Savings Bonds
30(1)
Qualified Tuition Programs
31(1)
Tax Benefit Rule
31(1)
Ethical Considerations: Unintentional Generosity of the Tax Benefit Rule
32(1)
Income from Discharge of Indebtedness
32(2)
Tax Planning Considerations
34(2)
Life Insurance
34(1)
Employee Benefits
34(1)
Investment Income
35(1)
Problem Materials
36
Deductions and Losses: In General
1(1)
Classification of Deductible Expenses
2(7)
Deductions for Adjusted Gross Income
3(1)
Itemized Deductions
4(1)
Trade or Business Expenses and Production of Income Expenses
5(1)
Tax in the News: Two Sides of an Issue: To Kick or to Receive?
6(1)
Business and Nonbusiness Losses
7(1)
Reporting Procedures
8(1)
Deductions and Losses---Timing of Expense Recognition
9(2)
Importance of Taxpayer's Method of Accounting
9(1)
Cash Method Requirements
9(1)
Accrual Method Requirements
10(1)
Disallowance Possibilities
11(19)
Public Policy Limitation
11(1)
Ethical Considerations: Knowing the Right People
12(2)
Political Contributions and Lobbying Activities
14(1)
Excessive Executive Compensation
14(1)
Tax in the News: Executive Pay Abuse
15(1)
Investigation of a Business
15(1)
Hobby Losses
16(1)
Ethical Considerations: When Is a Dairy Farm a Trade or Business?
17(2)
Rental of Vacation Homes
19(1)
Tax in the News: Can an Extreme Makeover Produce Extreme Taxes?
20(1)
Tax in the News: Vacation Homes for the Rich
21(4)
Expenditures Incurred for Taxpayer's Benefit or Taxpayer's Obligation
25(1)
Disallowance of Personal Expenditures
25(1)
Disallowance of Deductions for Capital Expenditures
26(1)
Transactions between Related Parties
26(2)
Substantiation Requirements
28(1)
Expenses and Interest Relating to Tax-Exempt Income
28(2)
Tax Planning Considerations
30(3)
Time Value of Tax Deductions
30(1)
Unreasonable Compensation
30(1)
Excessive Executive Compensation
30(2)
Shifting Deductions
32(1)
Hobby Losses
32(1)
Capital Expenditures
33(1)
Problem Materials
33
Deductions and Losses: Certain Business Expenses and Losses
1(1)
Tax in the News: A Deduction for Bad Debts
3(1)
Bad Debts
3(3)
Specific Charge-off Method
3(2)
Global Tax Issues: Writing Off Bad Debts in Australia
5(1)
Business versus Nonbusiness Bad Debts
5(1)
Global Tax Issues: Macau---The New Las Vegas?
6(1)
Loans between Related Parties
6(1)
Worthless Securities
6(2)
Small Business Stock
7(1)
Losses of Individuals
8(8)
Ethical Considerations: What Is a Casualty Loss?
9(1)
Events That Are Not Casualties
9(1)
Theft Losses
9(1)
When to Deduct Casualty Losses
10(1)
Measuring the Amount of Loss
11(3)
Statutory Framework for Deducting Losses of Individuals
14(1)
Personal Casualty Gains and Losses
14(2)
Ethical Considerations: The Amount of a Casualty Loss
16(1)
Research and Experimental Expenditures
16(2)
Expense Method
17(1)
Deferral and Amortization Method
17(1)
Manufacturers' Deduction
18(1)
Operational Rules
18(1)
Observations and Operational Problems
19(1)
Net Operating Losses
19(2)
Carryback and Carryover Periods
20(1)
Tax in the News: Increased Net Operating Loss Cap
21(1)
Tax Planning Considerations
21(2)
Tax Consequences of the Groetzinger Case
21(1)
Documentation of Related-Taxpayer Loans, Casualty Losses, and Theft Losses
21(1)
Tax in the News: New York at a Disadvantage
22(1)
Small Business Stock
22(1)
Casualty Losses
22(1)
Net Operating Losses
23(1)
Problem Materials
23
Depreciation, Cost Recovery, Amortization, and Depletion
1(1)
Overview
2(2)
General
2(1)
Concepts Relating to Depreciation
3(1)
Modified Accelerated Cost Recovery System (MACRS)
4(15)
Global Tax Issues: Changing the Life of a Truck
5(1)
Personalty: Recovery Periods and Methods
5(3)
Tax in the News: Capital Investment Write-Offs Reduce Corporate Taxes
8(1)
Realty: Recovery Periods and Methods
9(1)
Straight-line Election
10(1)
Election to Expense Assets
10(1)
Tax in the News: Changing Business Deductions
11(1)
Business and Personal Use of Automobiles and Other Listed Property
12(1)
Tax in the News: Spreading the Impact of the § 179 Expense Deduction
13(4)
Ethical Considerations: Substantiating Business Usage of an Automobile
17(1)
Alternative Depreciation System (ADS)
18(1)
Accelerated Cost Recovery System (ACRS)
19(1)
Amortization
20(1)
Ethical Considerations: Computing § 197 Amortization
20(1)
Depletion
20(4)
Intangible Drilling and Development Costs (IDC)
21(1)
Depletion Methods
21(3)
Tax Planning Considerations
24(2)
Cost Recovery
24(1)
Amortization
25(1)
Depletion
25(1)
Tables
26(6)
Problem Materials
32
Deductions: Employee and Self-Employed-Related Expenses
1(1)
Employee versus Self-Employed
3(1)
Tax in the News: Caddies or Golf Carts?
4(1)
Employee Expenses---In General
4(1)
Transportation Expenses
5(2)
Qualified Expenditures
5(1)
Computation of Automobile Expenses
6(1)
Travel Expenses
7(4)
Definition of Travel Expenses
7(1)
Away-from-Home Requirement
7(2)
Restrictions on Travel Expenses
9(1)
Combined Business and Pleasure Travel
10(1)
Global Tax Issues: Conventions in Faraway Lands
11(1)
Moving Expenses
11(2)
Distance Test
11(1)
Time Test
12(1)
Treatment of Moving Expenses
12(1)
Global Tax Issues: Expatriates and the Moving Expense Deduction
13(1)
Education Expenses
13(4)
General Requirements
13(1)
Requirements Imposed by Law or by the Employer for Retention of Employment
14(1)
Maintaining or Improving Existing Skills
14(1)
Tax in the News: Is an MBA Degree Deductible?
15(1)
Classification of Specific Items
15(1)
A Limited Deduction Approach
16(1)
Other Provisions Dealing with Education
17(1)
Entertainment Expenses
17(3)
Cutback Adjustment
17(1)
Ethical Considerations: Your Turn or Mine?
18(1)
Classification of Expenses
19(1)
Restrictions upon Deductibility
19(1)
Other Employee Expenses
20(4)
Office in the Home
20(2)
Tax in the News: One Side Effect of 9/11
22(1)
Miscellaneous Employee Expenses
22(2)
Contributions to Retirement Accounts
24(1)
Employee IRAs
24(1)
Self-Employed Keogh (H.R. 10) Plans
24(1)
Classification of Employee Expenses
24(3)
Accountable Plans
25(1)
Nonaccountable Plans
26(1)
Reporting Procedures
26(1)
Ethical Considerations: A Customized Reimbursement Agreement
27(1)
Limitations on Itemized Deductions
27(2)
Miscellaneous Itemized Deductions Subject to the 2 Percent Floor
28(1)
Ethical Considerations: Will Separate Returns by Married Persons Save Taxes?
28(1)
Miscellaneous Itemized Deductions Not Subject to the 2 Percent Floor
28(1)
Tax in the News: Relief for Members of the Armed Forces Reserves
29(1)
Tax Planning Considerations
29(3)
Self-Employed Individuals
29(1)
Ethical Considerations: Travel Expenses Can Be a Profit Center
30(1)
Shifting Deductions between Employer and Employee
30(1)
Transportation and Travel Expenses
30(1)
Moving Expenses
30(1)
Education Expenses
31(1)
Entertainment Expenses
31(1)
Unreimbursed Employee Business Expenses
32(1)
Problem Materials
32
Deductions and Losses: Certain Itemized Deductions
1(1)
General Classification of Expenses
2(1)
Tax in the News: The President and Vice President Itemize
3(1)
Medical Expenses
3(8)
General Requirements
3(1)
Medical Expenses Defined
3(2)
Capital Expenditures for Medical Purposes
5(1)
Medical Expenses Incurred for Spouse and Dependents
6(1)
Transportation, Meal, and Lodging Expenses for Medical Treatment
6(1)
Amounts Paid for Medical Insurance Premiums
7(1)
Year of Deduction
8(1)
Reimbursements
8(1)
Health Savings Accounts
9(2)
Taxes
11(3)
Deductibility as a Tax
11(1)
Property Taxes
12(1)
Global Tax Issues: Deductibility of Foreign Taxes
13(1)
State and Local Income Taxes and Sales Taxes
13(1)
Interest
14(5)
Allowed and Disallowed Items
14(4)
Restrictions on Deductibility and Timing Considerations
18(1)
Classification of Interest Expense
19(1)
Charitable Contributions
19(8)
Criteria for a Gift
20(1)
Qualified Organizations
21(1)
Global Tax Issues: Choose the Charity Wisely
22(1)
Time of Deduction
22(1)
Record-Keeping and Valuation Requirements
22(1)
Limitations on Charitable Contribution Deduction
23(1)
Tax in the News: Spring Cleaning and Charitable Contributions
23(4)
Miscellaneous Itemized Deductions
27(1)
Ethical Considerations: Job Hunting in Ski Country: A Deductible Expense?
28(1)
Other Miscellaneous Deductions
28(1)
Comprehensive Example of Schedule A
29(1)
Overall Limitation on Certain Itemized Deductions
29(4)
Tax in the News: The First Family and Itemized Deduction Phaseouts
32(1)
Ethical Considerations: Between a Rock and a Hard Place
32(1)
Tax Planning Considerations
33(3)
Effective Utilization of Itemized Deductions
33(1)
Utilization of Medical Deductions
33(1)
Timing the Payment of Deductible Taxes
33(1)
Protecting the Interest Deduction
34(1)
Assuring the Charitable Contribution Deduction
34(2)
Problem Materials
36
Passive Activity Losses
1(1)
The Tax Shelter Problem
2(1)
At-Risk Limits
3(3)
Tax in the News: With Tax Shelters in the Spotlight, Taxpayers Should Be Cautious!
4(2)
Ethical Considerations: Manipulating the At-Risk Limits
6(1)
Passive Loss Limits
6(19)
Classification and Impact of Passive Income and Losses
6(3)
Taxpayers Subject to the Passive Loss Rules
9(2)
Passive Activities Defined
11(9)
Interaction of the At-Risk and Passive Activity Limits
20(1)
Tax in the News: Newly Developed Tax Shelter Strategies Now Protected by Patents
21(1)
Special Passive Activity Rules for Real Estate Activities
21(3)
Ethical Considerations: How Active Is Active?
24(1)
Dispositions of Passive Interests
24(1)
Tax Planning Considerations
25(2)
Utilizing Passive Losses
25(2)
Problem Materials
27
Tax Credits
1(1)
Tax Policy Considerations
3(1)
Overview and Priority of Credits
4(3)
Refundable versus Nonrefundable Credits
4(1)
General Business Credit
5(1)
Treatment of Unused General Business Credits
6(1)
Specific Business-Related Tax Credit Provisions
7(8)
Tax Credit for Rehabilitation Expenditures
7(1)
Work Opportunity Tax Credit
8(1)
Welfare-to-Work Credit
9(1)
Research Activities Credit
10(2)
Low-Income Housing Credit
12(1)
Ethical Considerations: A Win-Win Situation or an Incalculable Loss?
13(1)
Disabled Access Credit
13(1)
Credit for Small Employer Pension Plan Startup Costs
14(1)
Credit for Employer-Provided Child Care
14(1)
Other Tax Credits
15(13)
Earned Income Credit
15(1)
Ethical Considerations: Snagging the Earned Income Credit with the Aid of a Transient Child
16(1)
Tax Credit for Elderly or Disabled Taxpayers
17(1)
Tax in the News: The Earned Income Credit: A Boost to the Working Poor and Merchants, Too!
18(1)
Foreign Tax Credit
19(1)
Global Tax Issues: Sourcing Income in Cyberspace---Getting It Right When Calculating the Foreign Tax Credit
20(1)
Adoption Expenses Credit
20(1)
Child Tax Credit
21(1)
Credit for Child and Dependent Care Expenses
21(2)
Education Tax Credits
23(2)
Credit for Certain Retirement Plan Contributions
25(3)
Tax Planning Considerations
28(2)
Foreign Tax Credit
28(1)
Credit for Child and Dependent Care Expenses
29(1)
Problem Materials
30
Property Transactions: Determination of Gain or Loss, Basis Considerations, and Nontaxable Exchanges
1(1)
Determination of Gain or Loss
3(6)
Realized Gain or Loss
3(1)
Tax in the News: Reevaluating Your Investment Strategy
4(2)
Ethical Considerations: Reporting a Distribution: Dividend or Return of Capital?
6(1)
Recognized Gain or Loss
7(1)
Nonrecognition of Gain or Loss
8(1)
Recovery of Capital Doctrine
8(1)
Basis Considerations
9(15)
Determination of Cost Basis
9(3)
Tax in the News: Frequent-Flier Miles and Basis
12(1)
Gift Basis
12(3)
Property Acquired from a Decedent
15(1)
Tax in the News: Effect of 2001 Tax Legislation on the Basis of Inherited Property: Bad News/Good News!
16(1)
Disallowed Losses
17(1)
Ethical Considerations: Transactions between Spouses
18(2)
Conversion of Property from Personal Use to Business or Income-Producing Use
20(1)
Additional Complexities in Determining Realized Gain or Loss
21(1)
Summary of Basis Adjustments
22(2)
General Concept of a Nontaxable Exchange
24(1)
Like-Kind Exchanges---§ 1031
25(7)
Like-Kind Property
26(1)
Ethical Considerations: An Assumption for a Related-Party Exchange
27(1)
Exchange Requirement
27(1)
Boot
28(1)
Basis and Holding Period of Property Received
29(3)
Involuntary Conversions---§ 1033
32(5)
Involuntary Conversion Defined
32(1)
Computing The Amount Realized
32(1)
Tax in the News: A Court Limits the Government's Taking of Property
33(1)
Replacement Property
34(1)
Time Limitation on Replacement
34(1)
Nonrecognition of Gain
35(2)
Involuntary Conversion of a Personal Residence
37(1)
Reporting Considerations
37(1)
Sale of a Residence---§ 121
37(7)
Requirements for Exclusion Treatment
37(1)
Tax in the News: A Tax Break for Those Who Serve
38(1)
Exceptions to the Two-Year Ownership Rule
39(1)
Calculation of the Amount of the Exclusion
40(2)
Tax in the News: The Gains Keep Growing
42(1)
Principal Residence
43(1)
Involuntary Conversion and Using §§ 121 and 1033
43(1)
Other Nonrecognition Provisions
44(2)
Exchange of Stock for Property---§ 1032
44(1)
Certain Exchanges of Insurance Policies---§ 1035
44(1)
Exchange of Stock for Stock of the Same Corporation---§ 1036
45(1)
Certain Reacquisitions of Real Property---§ 1038
45(1)
Transfers of Property between Spouses or Incident to Divorce---§ 1041
45(1)
Rollovers Into Specialized Small Business Investment Companies---§ 1044
45(1)
Rollover of Gain from Qualified Small Business Stock into Another Qualified Small Business Stock---§ 1045
46(1)
Tax Planning Considerations
46(6)
Tax Consequences of Alice's Proposed Transaction
46(1)
Cost Identification and Documentation Considerations
47(1)
Selection of Property for Making Gifts
47(1)
Selection of Property for Making Bequests
47(1)
Disallowed Losses
48(1)
Like-Kind Exchanges
49(1)
Involuntary Conversions
49(1)
Sale of a Principal Residence
50(1)
Ethical Considerations: A Realtor's Recommendation for the § 121 Exclusion
51(1)
Tax in the News: Sale of a Residence and the Home Office Deduction
51(1)
Problem Materials
52
Property Transactions: Capital Gains and Losses, § 1231, and Recapture Provisions
1(1)
General Considerations
3(1)
Rationale for Separate Reporting of Capital Gains and Losses
3(1)
General Scheme of Taxation
3(1)
Tax in the News: Switching Funds Creates a Loss
4(1)
Capital Assets
4(4)
Definition of a Capital Asset
4(2)
Ethical Considerations: Capital Assets for a Song
6(1)
Effect of Judicial Action
6(1)
Statutory Expansions
7(1)
Sale or Exchange
8(7)
Tax in the News: All Is Not Lost---It's Just Less Valuable
9(1)
Worthless Securities and § 1244 Stock
9(1)
Special Rule---Retirement of Corporate Obligations
9(1)
Options
10(1)
Patents
11(2)
Franchises, Trademarks, and Trade Names
13(2)
Lease Cancellation Payments
15(1)
Holding Period
15(5)
Tax in the News: How Long Was the Holding Period for That Property?
16(1)
Review of Special Holding Period Rules
16(1)
Special Rules for Short Sales
17(1)
Global Tax Issues: Trading ADRs on U.S. Stock Exchanges
18(2)
Tax Treatment of Capital Gains and Losses of Noncorporate Taxpayers
20(9)
Capital Gain and Loss Netting Process
21(3)
Ethical Considerations: Is That Capital Gain Taxable?
24(1)
Qualified Dividend Income
24(1)
Alternative Tax on Net Capital Gain
25(1)
Treatment of Capital Losses
26(1)
Tax in the News: Not All Corporate Dividends Are ``Qualified Dividends''
27(2)
Tax Treatment of Capital Gains and Losses of Corporate Tax Payers
29(1)
Overview of § 1231 and the Recapture Provisions
29(1)
Tax in the News: Capital Gain Confusion
30(1)
Section 1231 Assets
30(8)
Relationship to Capital Assets
30(1)
Justification for Favorable Tax Treatment
31(1)
Property Included
31(1)
Tax in the News: An Environmental Fight over Timber Cutting
32(1)
Property Excluded
32(1)
Section 1231 Assets Disposed of by Casualty or Theft
32(2)
Global Tax Issues: Canadian Slow Depreciation
34(1)
General Procedure For § 1231 Computation
34(4)
Section 1245 Recapture
38(3)
Ethical Considerations: Preparing Tax Returns without Proper Information
38(1)
Tax in the News: More Depreciation and More Depreciation Recapture
39(1)
Section 1245 Property
40(1)
Observations on § 1245
41(1)
Section 1250 Recapture
41(5)
Computing Recapture on Nonresidential Real Property
42(1)
Computing Recapture on Residential Rental Housing
43(1)
Section 1250 Recapture Situations
43(1)
Unrecaptured § 1250 Gain (Real Estate 25% Gain)
44(2)
Global Tax Issues: Exchange for Foreign Property Yields Recognized Recapture Gain
46(1)
Considerations Common to §§ 1245 and 1250
46(3)
Exceptions
46(1)
Other Applications
47(2)
Global Tax Issues: Depreciation Recapture in Other Countries
49(1)
Special Recapture Provisions
49(1)
Special Recapture for Corporations
49(1)
Gain from Sale of Depreciable Property between Certain Related Parties
49(1)
Intangible Drilling Costs
49(1)
Reporting Procedures
50(1)
Ethical Considerations: Flow-Through 25% Gain
50(1)
Tax Planning Considerations
50(5)
Importance of Capital Asset Status
50(1)
Planning for Capital Asset Status
50(1)
Global Tax Issues: Capital Gain Treatment in the United States and Other Countries
51(1)
Effect of Capital Asset Status in Transactions Other Than Sales
52(1)
Stock Sales
52(1)
Maximizing Benefits
53(1)
Year-End Planning
53(1)
Timing of § 1231 Gain
53(1)
Timing of Recapture
54(1)
Postponing and Shifting Recapture
54(1)
Avoiding Recapture
54(1)
Problem Materials
55
Alternative Minimum Tax
1(1)
Tax in the News: The AMT: From 155 to 33 Million
3(1)
Individual Alternative Minimum Tax
3(24)
AMT Formula for Alternative Minimum Taxable Income (AMTI)
3(3)
AMT Formula: Other Components
6(3)
Ethical Considerations: Minimizing the Tax Liability
9(1)
AMT Adjustments
9(12)
AMT Preferences
21(1)
Ethical Considerations: Tax-Exempt Bonds and the AMT
22(1)
Tax in the News: Distinguishing between Taxable and Exempt Bonds for AMT Purposes
23(1)
Illustration of the AMT Computation
23(3)
AMT Credit
26(1)
Corporate Alternative Minimum Tax
27(4)
Repeal of AMT for Small Corporations
28(1)
AMT Adjustments
28(2)
Tax Preferences
30(1)
Exemption
31(1)
Other Aspects of the AMT
31(1)
Tax Planning Considerations
31(2)
Responding to Bob and Carol
31(1)
Avoiding Preferences and Adjustments
31(1)
Controlling the Timing of Preferences and Adjustments
32(1)
Taking Advantage of the AMT/Regular Tax Rate Differential
32(1)
Problem Materials
33
Accounting Periods and Methods
1(1)
Accounting Periods
2(8)
In General
2(1)
Tax in the News: Producers' Deduction Creates Tax Planning Opportunities
3(1)
Specific Provisions for Partnerships, S Corporations, and Personal Service Corporations
3(3)
Making the Election
6(1)
Changes in the Accounting Period
6(1)
Taxable Periods of Less Than One Year
7(2)
Mitigation of the Annual Accounting Period Concept
9(1)
Ethical Considerations: Net Operating Loss Carryback Limits Can Put the Government Ahead of Creditors
10(1)
Accounting Methods
10(8)
Permissible Methods
10(1)
Cash Receipts and Disbursements Method---Cash Basis
11(1)
Tax in the News: Who Wants to Be a Producer?
12(1)
Accrual Method
13(1)
Tax in the News: Applying the All Events Test to Cooperative Advertising
14(2)
Hybrid Method
16(1)
Change of Method
16(2)
Special Accounting Methods
18(11)
Installment Method
18(5)
Disposition of Installment Obligations
23(1)
Interest on Deferred Taxes
24(1)
Electing Out of the Installment Method
24(1)
Ethical Considerations: Electing Out of Electing Out of the Installment Sale Method
25(1)
Long-Term Contracts
25(4)
Tax Planning Considerations
29(2)
Taxable Year
29(1)
Cash Method of Accounting
29(1)
Installment Method
29(1)
Completed Contract Method
30(1)
Problem Materials
31
Corporations: Introduction, Operating Rules, and Related Corporations
1(1)
Tax Treatment of Various Business Forms
2(7)
Sole Proprietorships
2(1)
Tax in the News: Corporate Tax Breaks
3(1)
Partnerships
3(1)
Regular Corporations
4(2)
Tax in the News: Impact of the Dividend Tax Cut
6(1)
Limited Liability Companies
7(1)
Global Tax Issues: Entity Choice: S Corporation versus C Corporation
8(1)
Entity Classification
8(1)
An Introduction to the Income Taxation of Corporations
9(11)
An Overview of Corporate versus Individual Income Tax Treatment
9(1)
Specific Provisions Compared
10(1)
Accounting Periods and Methods
10(1)
Capital Gains and Losses
11(1)
Passive Losses
12(1)
Charitable Contributions
13(1)
Ethical Considerations: Is It Better Not to Know?
14(1)
Manufacturers' Deduction
15(1)
Net Operating Losses
16(1)
Deductions Available Only to Corporations
17(3)
Determining the Corporate Income Tax Liability
20(7)
Corporate Income Tax Rates
20(1)
Alternative Minimum Tax
20(1)
Tax Liability of Related Corporations
21(1)
Controlled Groups
22(2)
Ethical Considerations: A Bookkeeper's Mistake
24(1)
Consolidated Returns
24(3)
Procedural Matters
27(3)
Filing Requirements for Corporations
27(1)
Estimated Tax Payments
28(1)
Reconciliation of Taxable Income and Financial Net Income
28(2)
Tax Planning Considerations
30(5)
Corporate versus Noncorporate Forms of Business Organization
30(1)
Operating the Corporation
31(1)
Related Corporations
32(3)
Problem Materials
35
Corporations: Organization and Capital Structure
1(1)
Organization of and Transfers to Controlled Corporations
2(12)
In General
2(1)
Global Tax Issues: Choice of Organizational Form When Operating Overseas
3(1)
Property Defined
4(1)
Stock Transferred
5(1)
Control of the Corporation
6(1)
Ethical Considerations: Proper Timing of a Gift of Shares
7(2)
Assumption of Liabilities---§ 357
9(3)
Basis Determination and Related Issues
12(2)
Global Tax Issues: Does § 351 Cover the Incorporation of a Foreign Business?
14(1)
Capital Structure of a Corporation
14(4)
Capital Contributions
14(1)
Debt in the Capital Structure
15(2)
Tax in the News: Conflict Arises between Corporations and Their Shareholders
17(1)
Investor Losses
18(3)
Stock and Security Losses
18(1)
Business versus Nonbusiness Bad Debts
18(2)
Section 1244 Stock
20(1)
Gain from Qualified Small Business Stock
21(1)
Tax Planning Considerations
21(4)
Working with § 351
21(2)
Selecting Assets To Transfer
23(1)
Ethical Considerations: The Control of a New Corporation: Insiders versus Outsiders
23(1)
Debt in the Capital Structure
23(1)
Investor Losses
24(1)
Problem Materials
25
Corporations: Distributions Not in Complete Liquidation
1(1)
Corporate Distributions---In General
3(1)
Earnings and Profits (E & P)
3(7)
Computation of E & P
3(3)
Summary of E & P Adjustments
6(1)
Current versus Accumulated E & P
6(1)
Allocating E & P to Distributions
7(2)
Ethical Considerations: Shifting E & P
9(1)
Dividends
10(10)
Rationale for Reduced Tax Rates on Dividends
11(1)
Qualified Dividends
11(1)
Property Dividends
12(1)
Tax in the News: Companies Pay Record Dividends in 2004
13(2)
Constructive Dividends
15(2)
Global Tax Issues: Deemed Dividends from Controlled Foreign Corporations
17(1)
Stock Dividends and Stock Rights
18(1)
Tax in the News: The REIT (Real Estate Investment Trust) Kind of Dividends
19(1)
Stock Redemptions
20(8)
Tax in the News: Corporate Cash Reserves Affect the Frequency of Stock Redemptions
20(1)
Overview
20(1)
Global Tax Issues: Foreign Shareholders Prefer Sale or Exchange Treatment in Stock Redemptions
21(1)
Historical Background
22(1)
Stock Attribution Rules
23(1)
Tax in the News: A Novel Interpretation of Stock Attribution Rules
24(1)
Not Essentially Equivalent Redemptions
24(1)
Disproportionate Redemptions
25(1)
Complete Termination Redemptions
26(1)
Ethical Considerations: A Friendly Dilemma
27(1)
Redemptions to Pay Death Taxes
27(1)
Effect on the Corporation Redeeming Its Stock
28(2)
Recognition of Gain or Loss
28(1)
Effect on Earnings and Profits
29(1)
Redemption Expenditures
30(1)
Other Corporate Distributions
30(1)
Tax Planning Considerations
30(5)
Corporate Distributions
30(1)
Ethical Considerations: Playing Games with the Statute of Limitations
31(1)
Planning for Qualified Dividends
31(1)
'Constructive Dividends
32(2)
Stock Redemptions
34(1)
Problem Materials
35
Corporations: Distributions in Complete Liquidation and an Overview of Reorganizations
1(1)
Liquidations---In General
2(2)
The Liquidation Process
2(1)
Liquidating and Nonliquidating Distributions Compared
3(1)
Liquidations---Effect on the Distributing Corporation
4(4)
The General Rule
4(1)
Antistuffing Rules
4(4)
Liquidations---Effect on the Shareholder
8(1)
The General Rule
8(1)
Ethical Considerations: Shareholder Liability for Tax Deficiency of Liquidated Corporation
8(1)
Special Rule for Certain Installment Obligations
8(1)
Liquidations---Parent-Subsidiary Situations
9(5)
Tax in the News: Include Intangible Assets When Determining a Subsidiary's Solvency
10(1)
Minority Shareholder Interests
10(1)
Indebtedness of the Subsidiary to the Parent
11(1)
Basis of Property Received by the Parent Corporation---The General Rule
11(1)
Global Tax Issues: Exception to § 332 for Liquidations of U.S. Subsidiaries of Foreign Corporations
12(1)
Basis of Property Received by the Parent Corporation---§ 338 Election
12(2)
Corporate Reorganizations
14(6)
In General
15(1)
Tax in the News: When Mergers and Acquisitions Rebound, So Does Hiring
16(1)
Summary of the Different Types of Reorganizations
16(1)
Summary of the Tax Consequences in a Tax-free Reorganization
17(3)
Tax Planning Considerations
20(2)
Effect of a Liquidating Distribution on the Corporation
20(1)
Effect of a Liquidating Distribution on the Shareholder
21(1)
Parent-Subsidiary Liquidations
21(1)
Asset Purchase versus Stock Purchase
22(1)
The Role of the Letter Ruling
22(1)
Problem Materials
22
Partnerships
1(1)
Overview of Partnership Taxation
2(8)
Forms of Doing Business---Federal Tax Consequences
2(1)
Tax in the News: Partnerships in the Movies
3(1)
What Is a Partnership?
4(1)
Tax in the News: The Growing Number of LLCs
5(1)
Elections Related to Partnership Status
5(1)
Partnership Taxation
5(2)
Partnership Reporting
7(1)
Partner's Ownership Interest in a Partnership
7(2)
Conceptual Basis for Partnership Taxation
9(1)
Anti-Abuse Provisions
9(1)
Formation of a Partnership: Tax Effects
10(10)
Gain or Loss on Contributions to the Partnership
10(1)
Exceptions to § 721
11(1)
Tax Issues Relative to Contributed Property
12(2)
Inside and Outside Bases
14(1)
Tax Accounting Elections
15(1)
Initial Costs of a Partnership
16(2)
Method of Accounting
18(1)
Taxable Year of the Partnership
18(2)
Operations of the Partnership
20(16)
Measuring and Reporting Income
20(3)
Ethical Considerations: A Preparer's Responsibility for Partners' Tax Returns
23(1)
Partnership Allocations
23(2)
Basis of a Partnership Interest
25(7)
Loss Limitations
32(4)
Transactions between Partners and Partnerships
36(3)
Guaranteed Payments
36(1)
Other Transactions between Partners and Partnerships
37(2)
Partners as Employees
39(1)
Distributions from the Partnership
39(8)
Proportionate Nonliquidating Distributions
40(4)
Proportionate Liquidating Distributions
44(3)
Sale of a Partnership Interest
47(3)
General Rules
48(1)
Effect of Hot Assets
49(1)
Limited Liability Entities
50(1)
Limited Liability Companies
50(1)
Limited Liability Partnerships
51(1)
Tax Planning Considerations
51(3)
Choosing Partnership Taxation
51(1)
Formation and Operation of a Partnership
51(1)
Transactions between Partners and Partnerships
52(1)
Global Tax Issues: Partnerships Around the World---and Beyond
53(1)
Drafting the Partnership Agreement
53(1)
Problem Materials
54
S Corporations
1(1)
Introduction
2(3)
An Overview of S Corporations
3(1)
When to Elect S Corporation Status
4(1)
Qualifying for S Corporation Status
5(6)
Definition of a Small Business Corporation
5(1)
Tax in the News: Flexibility with QSSSs
6(2)
Ethical Considerations: Extortion Payments
8(1)
Making the Election
8(1)
Shareholder Consent
9(1)
Loss of the Election
10(1)
Operational Rules
11(20)
Computation of Taxable Income
12(2)
Allocation of Income and Loss
14(1)
Tax Treatment of Distributions to Shareholders
15(4)
Tax Treatment of Property Distributions by the Corporation
19(1)
Shareholder's Basis
20(3)
Treatment of Losses
23(3)
Tax on Pre-election Built-in Gain
26(1)
Ethical Considerations: A Helpful Appraisal
26(3)
Passive Investment Income Penalty Tax
29(1)
Other Operational Rules
30(1)
Tax Planning Considerations
31(11)
When the Election Is Advisable
31(1)
Making a Proper Election
31(1)
Preserving the Election
32(1)
Planning for the Operation of the Corporation
32(1)
Tax in the News: An Abusive Tax Shelter?
33(5)
Overall Comparison: Forms of Doing Business
38(4)
Problem Materials
42
Exempt Entities
1(1)
General Considerations
2(2)
Tax in the News: Tax-Exempts: Here Comes the IRS and Maybe Congress
3(1)
Types of Exempt Organizations
4(1)
Requirements for Exempt Status
4(3)
Serving the Common Good
4(1)
Not-for-Profit Entity
4(1)
Net Earnings and Members of the Organization
4(2)
Tax in the News: Class-Action Lawsuits Challenge Differential Fees
6(1)
Ethical Considerations: For the Good of the People
6(1)
Political Influence
7(1)
Tax Consequences of Exempt Status: General
7(4)
Prohibited Transactions
7(3)
Feeder Organizations
10(1)
Private Foundations
11(5)
Tax Consequences of Private Foundation Status
11(1)
Ethical Considerations: A Charity Documents the Value of Charitable Contributions
11(2)
Tax in the News: A Major Contribution to the Salvation Army
13(1)
Taxes Imposed on Private Foundations
13(3)
Unrelated Business Income Tax
16(9)
Unrelated Trade or Business
16(3)
Unrelated Business Income
19(1)
Unrelated Business Taxable Income
20(2)
Unrelated Debt-Financed Income
22(3)
Reporting Requirements
25(2)
Obtaining Exempt Organization Status
25(1)
Annual Filing Requirements
25(1)
Disclosure Requirements
26(1)
Tax Planning Considerations
27(3)
General
27(1)
Maintaining Exempt Status
27(1)
Tax in the News: Charities and Vehicle Donation Programs
28(1)
Private Foundation Status
28(1)
Unrelated Business Income Tax
29(1)
Problem Materials
30
Multistate Corporate Taxation
1(1)
Overview of Corporate State Income Taxation
3(6)
Ethical Considerations: Encouraging Economic Development through Tax Concessions
4(1)
Computing State Income Tax
4(1)
Tax in the News: Britney, You Need to Pay Your Tax
5(1)
Operational Implications
5(1)
State Modifications
6(3)
Jurisdiction to Impose Tax: Nexus and Public Law 86--272
9(1)
Allocation and Apportionment of Income
9(12)
The Apportionment Procedure
11(1)
Business and Nonbusiness Income
11(2)
Apportionment Factors: Elements and Planning
13(3)
The Sales Factor
16(1)
The Payroll Factor
17(2)
The Property Factor
19(2)
The Unitary Theory
21(4)
What Is a Unitary Business?
22(1)
Tax Effects of the Unitary Theory
22(3)
Global Tax Issues: Water's Edge Is Not a Day at the Beach
25(1)
Taxation of S Corporations
25(1)
Eligibility
26(1)
Taxation of Partnerships and LLCs
26(1)
Other State and Local Taxes
27(2)
State and Local Sales and Use Taxes
27(1)
Ethical Considerations: Taxing Clicks and Bricks
27(1)
Tax in the News: Collecting Those Sales/Use Tax Revenues
28(1)
Local Property Taxes
28(1)
Other Taxes
29(1)
Tax Planning Considerations
29(5)
Selecting the Optimal State in Which to Operate
29(2)
Restructuring Corporate Entities
31(1)
Subjecting the Corporation's Income to Apportionment
31(1)
Ethical Considerations: Can You Be a Nowhere Adviser?
32(1)
Planning with Apportionment Factors
32(1)
Sales/Use Taxes on Capital Changes
33(1)
Problem Materials
34
Taxation of International Transactions
1(1)
Overview of International Taxation
2(1)
Tax Treaties
3(2)
Global Tax Issues: Other Countries' Taxes Are Strange, Too
4(1)
Global Tax Issues: Why the Treaty Process Stalls
5(1)
Sourcing of Income and Deductions
5(6)
Income Sourced Inside the United States
5(3)
Income Sourced Outside the United States
8(1)
Tax in the News: Sourcing Income in Cyberspace
9(1)
Allocation and Apportionment of Deductions
9(1)
Section 482 Considerations
10(1)
Tax in the News: APAs Reduce Uncertainty in Transfer Pricing Disputes
11(1)
Foreign Currency Transactions
11(3)
Tax Issues
12(1)
Functional Currency
12(1)
Branch Operations
13(1)
Distribution from Foreign Corporations
13(1)
Foreign Taxes
13(1)
Section 988 Transactions
14(1)
U.S. Persons with Foreign Income
14(16)
Export Property Tax Incentives
14(1)
Cross-Border Asset Transfers
15(2)
Global Tax Issues: Boom in Cross-Border Mergers
17(1)
Tax Havens
18(1)
Foreign Corporations Controlled by U.S. Persons
19(1)
Ethical Considerations: A Boost to Domestic Investment or a Tax Amnesty for Outsourcers?
19(1)
Tax in the News: A Move to the Beach for U.S. Corporations Seeking a Vacation from U.S. Tax Rules
20(1)
Tax in the News: Who Are These CFCs?
21(3)
The Foreign Tax Credit
24(6)
U.S. Taxation of Nonresident Aliens and Foreign Corporations
30(7)
Nonresident Alien Individuals
30(1)
Ethical Considerations: Should There Be Some ``Heart'' in Tax Law?
31(2)
Foreign Corporations
33(2)
The Foreign Investment in Real Property Tax Act
35(2)
Expatriation to Avoid U.S. Taxation
37(1)
Tax Planning Considerations
37(3)
The Foreign Tax Credit Limitation and Sourcing Provisions
37(1)
The Foreign Corporation as a Tax Shelter
38(1)
Planning under Subpart F
39(1)
Using the Check-the-Box Regulations
39(1)
Transferring Intangible Assets Offshore
39(1)
Problem Materials
40
Tax Administration and Practice
1(1)
Tax Administration
2(20)
Tax in the News: Should the IRS Be Larger?
3(1)
Tax in the News: IRS Audit Initiatives
4(1)
IRS Procedure---Letter Rulings
4(1)
IRS Procedure---Other Issuances
5(1)
Administrative Powers of the IRS
6(1)
The Audit Process
7(2)
Tax in the News: Collecting Those Taxes Due
9(1)
The Taxpayer Appeal Process
10(1)
Offers in Compromise and Closing Agreements
11(1)
Interest
12(1)
Taxpayer Penalties
13(3)
Global Tax Issues: Advance Pricing Agreements Reduce International Uncertainty
16(1)
Ethical Considerations: Good Faith Valuations
17(3)
Tax in the News: Where Are All the Tax Criminals?
20(1)
Statutes of Limitations
20(2)
Tax Practice
22(7)
The Tax Practitioner
22(4)
Ethical Considerations: Where Does My Cost Saving Go?
26(1)
AICPA Statements on Standards for Tax Services
26(3)
Tax Planning Considerations
29(4)
Strategies in Seeking an Administrative Ruling
29(1)
Considerations in Handling an IRS Audit
30(1)
Ethical Considerations: Should the Client Attend an Audit?
30(2)
Penalties
32(1)
Problem Materials
33
The Federal Gift and Estate Taxes
1(1)
Transfer Taxes---In General
2(8)
Nature of the Taxes
2(1)
Tax in the News: An Erratic Approach to Transfer Taxes
3(1)
Global Tax Issues: Expatriation to Avoid U.S. Taxes
4(4)
Tax in the News: What Are the Chances?
8(1)
Valuation for Estate and Gift Tax Purposes
8(1)
Ethical Considerations: An Executor's Prerogative
9(1)
Key Property Concepts
9(1)
The Federal Gift Tax
10(9)
General Considerations
10(2)
Ethical Considerations: What Constitutes Support?
12(1)
Transfers Subject to the Gift Tax
12(2)
Annual Exclusion
14(1)
Deductions
15(1)
Tax in the News: Section 529 Plans Need Reevaluation
16(1)
Computing the Federal Gift Tax
16(2)
Procedural Matters
18(1)
The Federal Estate Tax
19(18)
Gross Estate
19(9)
Taxable Estate
28(1)
Ethical Considerations: The Advantage of Being Paid Up!
29(2)
Ethical Considerations: It's the Thought That Counts
31(2)
Computing the Federal Estate Tax
33(1)
Estate Tax Credits
34(1)
Tax in the News: Be Careful Where You Die!
35(1)
Global Tax Issues: Treaty Relief Is Not Abundant!
36(1)
Procedural Matters
36(1)
The Generation-Skipping Transfer Tax
37(1)
The Problem
37(1)
The Solution
37(1)
Tax Planning Considerations
38(4)
The Federal Gift Tax
38(1)
The Federal Estate Tax
39(3)
Problem Materials
42
Income Taxation of Trusts and Estates
1(1)
An Overview of Subchapter J
2(4)
What Is a Trust?
4(1)
Other Definitions
4(1)
What Is an Estate?
5(1)
Tax in the News: Should Your Trust Be All in the Family?
6(1)
Nature of Trust and Estate Taxation
6(3)
Filing Requirements
7(1)
Tax Accounting Periods, Methods, and Payments
7(1)
Tax Rates and Personal Exemption
7(1)
Alternative Minimum Tax
8(1)
Tax in the News: Everyone Gets Wet When You Soak the Rich
9(1)
Taxable Income of Trusts and Estates
9(12)
Entity Accounting Income
9(3)
Tax in the News: Pick the Home State for Your Trust Carefully
12(1)
Gross Income
12(2)
Tax in the News: Coordinate Your Deductions
14(1)
Ordinary Deductions
15(1)
Deductions for Losses
16(1)
Charitable Contributions
17(1)
Deduction for Distributions to Beneficiaries
17(4)
Tax Credits
21(1)
Taxation of Beneficiaries
21(5)
Distributions by Simple Trusts
21(1)
Distributions by Estates and Complex Trusts
22(1)
Character of Income
23(2)
Losses in the Termination Year
25(1)
Tax in the News: Don't Trust Your Dictionary
26(1)
Tax Planning Considerations
26(3)
A Trust or Estate as an Income-shifting Device
26(1)
Income Tax Planning for Estates
27(1)
Ethical Considerations: Should a Tax Adviser Also Be a Trustee?
28(1)
Income Tax Planning with Trusts
29(1)
Distributions of In-Kind Property
29(1)
Problem Materials
29
APPENDIXES
Tax Rate Schedules and Tables
1(1)
Tax Forms
1(1)
Glossary of Key Terms
1(1)
Table of Code Sections Cited
1(12)
Table of Regulations Cited
13(4)
Table of Revenue Procedures and Revenue Rulings Cited
17
Comprehensive Tax Return Problems
1(1)
Subject Index 1


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