CB 251-257 CHAPTER FIVE
more than $500,000 of E & P, the E & P reduction will be $100,000
regardless of which form is used.
Page 257: PROBLEM
(a).
(b).
(c) .
This basic planning problem, which covers the income tax consequences of
buy-sell agreements, i
FUNDAMENTALS OF
CORPORATE
TAXATION 8TH
EDITION SOLUTIONS
If you need to have a one stop search and find the proper manuals for your
products, you can go to this web site that gives many fundamentals of
corporate taxation 8th edition solutions. You may get
CHAPTER 16 Accounting for Income Taxes 909
O. 1 6—3 Sometimes a temporary difference will-produce future-deductible amounts. Explain what. is meant by future
deductible amounts. Describe two general situations that have this effect. How are such situation
FIN 48 Compliance: Disclosing Tax Positions in an Age of Uncertainty
1 of 12
http:/www.aicpa.org/publications/taxadviser/2008/jan/pages/fin48compl.
FIN 48 Compliance: Disclosing Tax Positions in an Age of Uncertainty
by Cherie J. Hennig, William A. Raabe,
364 U.S. 361 (1960)
KNETSCH ET UX.
v.
UNITED STATES.
No. 23.
Supreme Court of United States.
Argued October 17-18, 1960.
Decided November 14, 1960.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
W. Lee McLane, Jr. argued the cause
New Code Provision on the Economic Substance Doctrine
Janice
Eiseman
Very difficult to apply, but necessary to understand in light of the strict liability penalties
associated with the new provision.
June 21, 2010
by Janice Eiseman, JD, LLM
On March 30, 2
ALLIED DOMECQ SPIRITS & WINES USA, INC.,
vs.
COMMISSIONER OF REVENUE.
No. 13-P-984.
Appeals Court of Massachusetts.
Entered: June 18, 2014.
By the Court (Grainger, Rubin & Hanlon, JJ.)
Decisions issued by the Appeals Court pursuant to its rule 1:28 are
pr
TAX 6105 001
10695
Corporate Taxation
Spring 2014
ED 114
Thursdays, 7:10-10pm
Professor Information
Instructor: Ken Orbach
Office: DS 101B
E-mail: [email protected]
Phone: 561-297-2779
Webpage: http:/www.soa.fau.edu/orbach
Office Hours
Please contact me for
Redemptions Not Essentially Equivalent to Dividends
The M&A Tax Report (July 2011)
By Robert W. Wood
http:/www.woodllp.com/Publications/Articles/pdf/Redemptions_Not.pdf
There are many ways a shareholder can transfer stock out of their name, this can be ac
Redemptions Not Essentially Equivalent to
Dividends
By Robert W. Wood Wood & Porter San Francisco
But is it so simple? Some dividends do not
qualify for the 15-percent rate. Even more
obviously, if one receives sale or exchange
treatment, payments can be
Corporate Taxation
Disproportionate Example
Summer 2015
Total shares
Beginning
Redeemed shares
Total after
redemption
The Gremlin
28
Captain America
25
25
The Green Hornet
23
23
Wonder Woman
24
24
Totals
100
(7)
21
(7)
93
Part 2
Total shares
Beginning
Red
Checkpoint Contents
Federal Library
Federal Editorial Materials
Federal Tax Coordinator 2d
Chapter F-6990 Carryovers, Loss Corporations, Stock/Asset Purchases, E&P,
Redemptions, Liquidations
F-11400 Redemptions Not Essentially Equivalent to a Dividend.
Chapter 5
REDEMPTIONS AND PARTIAL LIQUIDATIONS
Significant Changes om the Seventh Edition:
1. The discussion of basis consequences in Section A (Introduction)
was updated to incorporate proposed regulations issued in 2009.
The problem on buysell agreement
Chapter 4
NONLIQUIDATING DISTRIBUTIONS
Significant Changes om the Seventh Edition:
1. The Note following Revenue Ruling 74464 was expanded to
include a brief discussion of the treatment of return of capital
distributions to shareholders holding multiple t
REDEMPTIONS AND PARTIAL LIQUIDA TIONS CB 205-221
under 302(b)(2). But the redemption likely would qualify under 302(b)(1)
since Don no longer has voting control of Z.
Page 221: PROBLEMS
1(a).
1(b).
1(c).
1(d).
The question throughout this problem is whe
ECONOMIC SUBSTANCE DOCTRINE
1. Clarification of the economic substance doctrine
Present Law
In general
The Code provides detailed rules specifying the computation of taxable income,
including the amount, timing, source, and character of items of income, g
