LAW 215: FEDERAL INCOME TAX

Size: px
Start display at page:

Download "LAW 215: FEDERAL INCOME TAX"

Transcription

1 LAW 215: FEDERAL INCOME TAX Schedule: Professor: Tuesdays and Thursdays, 5:30pm 7:00pm Christine Kim Phone: Office: Room 439 Office hours: Required texts: Tuesdays and Thursdays, 4pm 5pm or by appointment Freeland, Lathrope, Lind, and Stephens ( FLLS ), Fundamentals of Federal Income Taxation (Seventeenth Edition) I. Course Description Lathrope, Selected Federal Taxation Statutes and Regulations (2015 Edition) This is an introductory course in federal income taxation. Students will become familiar with the major sources of tax law, including the Internal Revenue Code (the Code ), Treasury Regulations, and administrative rulings of the Internal Revenue Service (the IRS or the Service ). Over the course of the semester, students will learn about the definition of gross income, certain statutory and administrative exclusions from gross income, allowable deductions and restrictions on deductions, characterization of income as capital gain or loss or ordinary income or loss, and timing rules that determine when income is recognized. By the end of the semester, students will be able to calculate tax liability, given a taxpayer s particular set of facts and circumstances. II. Syllabus The following syllabus is for planning purposes but is subject to change: CLASS 1: INTRODUCTION AND DEFINITION OF GROSS INCOME Reading: Skim FLLS Chapter 1, p FLLS Chapter 2, p Code Section 61

2 Treas. Reg (a); (d)(1); (a) Assignment: p. 54 Problems 1 6 p. 57 Problems 1 2 Reading: FLLS Chapter 3, p CLASS 2: EXCLUSION OF GIFTS AND INHERITANCES Code Section 102 Treas. Reg Assignment: p. 69 Problem 2 p. 70 Problems 1 3 p. 77 Problems 1 3 CLASS 3: EXCLUSION OF FRINGE BENEFITS AND AWARDS Reading: FLLS Chapter 4, p Code Sections 119; 132 Skim Code Sections 79; 83; 105; 106; 125; 127; 129; 137 Treas. Reg (a) and (b); (a), (c); (a)(1) (4), (e); (a)(1)(i), (a)(1)(iv); (b)(1); (a) (c); (e) Skim Treas. Reg (b)(1) FLLS Chapter 5, p Assignment: p. 87 Problem 1 Code Sections 74, 102(c), 132(a)(4), (3), 274(j) Treas. Reg ; Prop. Reg (b) p. 91 Problems 1 3 p. 98 Problems 1 2 p. 100 Problems 1 2 Reading: FLLS Chapter 6, p CLASS 4: GAIN FROM DEALINGS IN PROPERTY

3 Code Sections 1001; 1011; 1012; 109; 1016(a)(1); 1019 Treas. Reg (a); (a) (c); (a); (d)(2)(i) Assignment: p. 106 Problems 1 2 p. 113 Problems 1 2 p. 115 Problem 1 p. 118 Problem 1 p. 135 Problems 1 2 Reading: FLLS Chapter 8, p CLASS 5: DISCHARGE OF INDEBTEDNESS Code Sections 61(a)(12); 102(a); 108(a), (b)(1) (3), (d)(1) (5), (e)(1), (e)(5); 1017(a), (b)(1), (2), (3)(A), (3)(B) Skim Code Sections 108(c), (f), and (g); 385 Assignment: p. 162 Problems 1 4 Reading: FLLS Chapter 10, p CLASS 6: SEPARATION AND DIVORCE Code Sections 71(a) (c); 215(a) and (b); 7701(a)(17); 1041 Treas. Reg T(a) and (b); T(b) Assignment: p. 184 Problems 1 2 p. 197 Problem 1 p. 198 Problem 1 CLASS 7: ADDITIONAL STATUTORY EXCLUSIONS FROM GROSS INCOME Reading: FLLS Chapter 11, Code Sections 121, 25A, 135, 529, 530; 103; 115; 141(a) and (e) Skim Code Sections 911; 72(e)(2)(B), (e)(8)(b) and (e)(9); 117, 127, 132(c)(3); 221; 222; 141, 142, 148, 149 Treas. Reg

4 Assignment: p. 210 Problems 1 5 p. 219 Problems 1 2 Reading: FLLS Chapter 12, p CLASS 8: ASSIGNMENT OF INCOME Code Sections 1(a) (e), 1(h); 6013(a) Skim Code Sections 1(g), 63, 66, 73 Assignment: p. 238 Problem 1 p. 255 Problems 1 3 CLASS 9: BUSINESS DEDUCTIONS: EXPENSES OR CAPITAL EXPENDITURES? Reading: FLLS Chapter 14, p Code Sections 162(a); 263(a); 195; 262 Skim 263A Treas. Reg (a); T(a); 1.263(a) 2T(d)(1), (d)(2) (not in Lathrope Statutes and Regulations); 1.263(a) 3T(d), (e)(2)(i) and (e)(3)(i), (g)(1), (h)(1), (4), (i)(1), (5) examples 12 and 13, (j)(1) (not in Lathrope Statutes and Regulations); 1.263(a) 4(a) (c)(1), (d)(1), (e)(1)(i), (4)(i); 1.263(a) 5(a), (b)(1); (b) Assignment: p. 293 Problems 1 2 p. 310 Problems 1 3 p. 317 Problems 1 2 Reading: FLLS Chapter 14, p CLASS 10: SPECIFIC BUSINESS DEDUCTIONS Code Sections 162(a); 262; 274(a), (d), (e), (k), (l), (m)(2), (n)(1); 165(a) (c); 280B Skim Code Sections 162(m); 280G; 162(h); 274(c), (h), (m)(1) and (3) Treas. Reg ; ; ; ; (a); (a), (b)(1), (2)(i), 3(i), (c), (e)(1); (a)(2); (a)(1), (c), (d) Assignment: p. 330 Problem 1 p. 346 Problems 1 5

5 p. 358 Problems 1 4 p. 365 Problems 1 3 p. 368 Problem 1 Reading: FLLS Chapter 14, p CLASS 11: DEPRECIATION AND AMORTIZATION Code Sections 167(a), (c); 168(a) (c), (e)(1) and (2), (f)(1) and (5), (g)(1), (2), and (7), (i)(1); 1016(a)(2) Skim Code Sections 62(a)(1) and (4); 168(d); 263(a); 263A Treas. Reg ; 1.167(a) 1(a); 1.167(a) 10; 1.167(b) 0(a); 1.167(b) 1(a); 1.167(b) 2(a) Assignment: p. 391 Problems 1 2 CLASS 12: SPECIAL DEPRECIATION RULES AND BONUS DEPRECIATION Reading: FLLS Chapter 14, p Code Sections 167(a), (c)(1); 168(a) (c), (d)(1), (3) and (4)(A) and (C), (e)(1) (3), (f)(1) and (5), (g)(1)(e), (2), (3)(D), and (7), (i)(1), (k)(1), (2)(A), and (5); 179; 280F(a), (b), (d); Skim Code Section 197; 42; 46(1); 47(a) and (c) Assignment: p. 400 Problems 1 4 p. 405 Problem 1 CLASS 13: DEDUCTIONS FOR PROFIT MAKING, NONBUSINESS ACTIVITIES Reading: FLLS Chapter 15, Code Sections 212; 274(h)(7); 121(a), (d)(6); 165(a), (b), (c)(2); 167(a)(2); 168(a) Skim Code Sections 195; 280A Treas. Reg (g), (k), (l), (m); (b)(7); (b); 1.167(g) 1; (h) Assignment: p. 425 Problems 1 3 p. 433 Problems 1 3 CLASS 14: OTHER DEDUCTIBLE PERSONAL EXPENSES INTEREST AND TAXES

6 Reading: FLLS Chapter 16, p Code Sections 163(a), (h); 280A(d)(1); 7872; 164(a), (b)(1) and (5), (c), (d)(1); 275; 1001(b)(2) Skim Code Sections 163(d) and (f); 221; 263A; 265(a)(2) (4); 266 Treas. Reg (a) (d) Prop. Reg (a) Assignment: p. 465 Problems 1 5 p. 469 Problems 1 5 CLASS 15: OTHER DEDUCTIBLE PERSONAL EXPENSES DEDUCTIONS FOR INDIVIDUALS ONLY Reading: FLLS Chapter 18, p Code Sections 62(a), (c) and (e); 274(n)(1); 82; 132(a)(6) and (g); 217; 213(a), (b), (d)(1) (4) and (9); 263(a)(1); 25A(f); 222; 151; 152; 63; 67 Skim Code Sections 86(a) (c); 21; 152; 162(l); 213(d)(5) and (e); 25A; 135; 151(d)(2); 529; 530; 71(a), (c); 215; 6013(a), (d); 7703; 68 Treas. Reg T(b) and (d); (b) and (e)(3); (b) and (c)(2); T(a) Skim Treas. Reg ; (b)(2) (4), (8); (a)(1), (e)(1) (4)(i)(a) Assignment: p. 513 Problem 1 p. 517 Problems 1 3 p. 527 Problems 1 3 p. 529 Problems 1 2 p. 533 Problems 1 5 p. 543 Problems 1 7 CLASS 16: RESTRICTIONS ON DEDUCTIONS AT RISK RULES AND HOBBY LOSSES, HOME DEDUCTIONS, PASSIVE ACTIVITY LOSSES, AND ILLEGAL OR PROPERTY ACTIVITY Reading: FLLS Chapter 17, p

7 Code Sections 465(a), (b), (d), (e)(1); 183(a) (d); 280A(a), (b), (c)(1), (3), and (5), (d)(1), (e) (g); 469(a), (b), (c)(1), (2) and (7), (d), (e)(1), (f), (g), (h)(1) and (2), (i)(1) (3)(A) and (6), (j)(1), (l)(1); 162(c), (f), (g) Skim Code Sections 1(a); 152(f)(3); 162(e); 165(d); 280E; 6013 Treas. Reg (a) and (b); (a), (c), (e), and (f)(1); T(a), (b)(2)(ii), (iii), (c), (d) Assignment: p. 477 Problems 1 2 p. 486 Problem 1 p. 490 Problems 1 3 p. 502 Problems 1 7 CLASS 17: TIMING OF INCLUSION OR DEDUCTION CASH METHOD OF ACCOUNTING Reading: FLLS Chapter 19, p Code Sections 441(a) (e); 442; 446; 451(a); 461(a) Skim Code Sections 448; 460 Treas. Reg (a)(1) and (2), (b)(1), (c)(1)(i), (iv); (a), Assignment: p. 573 Problems 1 2 CLASS 18: TIMING OF INCLUSION OR DEDUCTION ACCRUAL METHOD OF ACCOUNTING Reading: FLLS Chapter 19, p Code Sections 451(a); 448(d)(5); 455; 456; 458; 461(a), (f) and (h) Treas. Reg (a); (a)(2); (a); (a) and (b)(1) Assignment: p. 602 Problems 1 4 p. 605 Problems 1 2 Reading: FLLS Chapter 20, p CLASS 19: THE TAXABLE YEAR Code Sections 1341(a), (b)(1) and (2); 111(a) Skim Code Sections 111(b) and (c); 172

8 Treas. Reg (a), (b)(1)(i) and (ii), Assignment: p. 617 Problems 1 2 Reading: FLLS Chapter 21, p CLASS 20: CAPITAL GAINS AND LOSSES Code Sections 1(c), (h); 1222; 1211(b); 1212(b)(1), (2)(A)(i); 1222; 1221(a)(1) (4); 1223(1), (2), (9); 102(b); 273; 1001(e); 1241 Skim Code Sections 1(a) (e), (i)(3)(b); 1201(a); 1202(a) (e); 1221(a)(1) (4); 1411; 165(c) and (f); 1211(a); 1212(a)(1) (4); 1222; 1221(a)(5) (8), (b); 1235; 1241; 1253; 1271; 1014(a); 1015(a); 1041(b)(2); 1233; 1259 Assignment: p. 646 Problems 1 3 p. 651 Problem 1 p. 666 Problem 1 p. 671 Problems 1 3 p. 683 Problems 1 4 CLASS 21: CAPITAL GAINS AND LOSSES, CONTINUED Reading: FLLS Chapter 21, p CLASS 22: STATUTORILY CREATED CAPITAL GAINS AND LOSSES Reading: FLLS Chapter 21, p Code Sections 1231 Skim Code Sections 165(g); 166(d); 1222; 1234; 1234A; 1235; 1236; 1237; 1241; 1253; 1271; 1(h); 1060; 1211(b); 1221(a)(1) (4); 1222 Assignment: p. 705 Problems 1 3 CLASS 23: CHARACTERIZATION ON THE SALE OF DEPRECIABLE PROPERTY Reading: FLLS Chapter 22, p Code Sections 267(b)(3), (10), (11) and (12) and (c); 318(a)(3)(B)(i); 1239; 64; 1245(a)(1) (3), (b)(1) and (2), (c), (d); 1(h)(1), (3), and (6); 1250(a)(1)(A) and (B)(v), (b)(1), (3) and (5), (c), (d)(1) and (2), (g) and (h)

9 Skim Code Sections 179(d)(10); 1041(b); 1222; 1231; 64 Treas. Reg (a)(1), (b), (c)(1), (d); (a)(1) (3)(i) and (7); (a) Assignment: p. 712 Problem 1 p. 717 Problems 1 2 p. 720 Problems 1 3 Reading: FLLS Chapter 23, p CLASS 24: CHARACTER OF CERTAIN DEDUCTIONS Code Sections 165(g)(1) and (2); 166(a) (e); 6511(d)(1); 170(a)(1), (b)(1)(a) (D), (G), (b)(2), (c), (e)(1), (2), and (5), (f)(8), (11), and (12), (i) and (j); 1011(b); 165(a) (c), (e), (h), (i), (k) Skim Code Sections 62; 111(a); 271(a); 448(d)(5); 67(b)(4); 162(b); 170(d)(1)(A), (f)(1) (4), (g), (l), 501(k); 67(b)(3); 123 Treas. Reg (a) (c), (e); (a)(1) (3), (5), (b)(1) and (3) ex. 1; (a)(1) (2), (c), (d); (c), (d)(1), (e) (g); (a) (b); (a) (b); (d)(1) (3); (a) and (d) Assignment: p. 735 Problems 1 2 p. 755 Problems 1 5 p. 765 Problems 1 2 Reading: FLLS Chapter 26, p CLASS 25: NONRECOGNITION PROVISIONS Code Sections 1001(c); 1031; 1223(1); 1033(a)(1), (a)(2), (b)(2), (g)(1), (2), and (4), (h)(2); 1223(1) Skim Code Sections 121(d)(10); 1245(b)(4); 1250(d)(4); 357(d)(1); 1231; 1245(b)(4); 1250(d)(4); 1038; 1044; 1045 Treas. Reg (a) 1; (a) 2(a); (b) 1(b) ex. 1; (d) 1; (k) 1(a) (c)(1) and (4)(i), (f); (d); (b) 1(b) Skim Treas. Reg (b) 1(c); (d) 2 Assignment: p. 841 Problems 1 5

10 p. 851 Problems 1 6 CLASS 26: COMPUTATIONS CALCULATING TAX LIABILITY Reading: FLLS Chapter 27, p Code Sections 1; 2; 68; 151(d)(3) and (4); 1411; 6013(a) and (d); 55(a) (d); 56(a)(1), (3), (4), and (6); (b)(1) and (3); 57(a)(5), (6), and (7); 58(b) Skim Code Sections 3; 63; 66; 67; 73; 6012; 7703; 21; 23; 24; 25A; 32; 31; 35; 6315; 6654 Assignment: p. 871 Problems 1 4 p. 889 Problem 1

Federal Income Tax and Policy Syllabus Professor Cauble Phone: , Office in Room 704 Fall 2014

Federal Income Tax and Policy Syllabus Professor Cauble   Phone: , Office in Room 704 Fall 2014 Federal Income Tax and Policy Syllabus Professor Cauble E-mail: ecauble@depaul.edu Phone: 312-362-5948, Office in Room 704 Fall 2014 Course Materials: There are two required books for the course: (1) Bankman,

More information

CORPORATE TAXATION LAW 783, SEC. 1, RM 210 SPRING SEMESTER 2018 (UPDATED JANUARY 4, 2018)

CORPORATE TAXATION LAW 783, SEC. 1, RM 210 SPRING SEMESTER 2018 (UPDATED JANUARY 4, 2018) CORPORATE TAXATION LAW 783, SEC. 1, RM 210 SPRING SEMESTER 2018 (UPDATED JANUARY 4, 2018) PROFESSOR AITSEBAOMO 3100 CLEBURNE STREET HOUSTON, TEXAS 77004 TELEPHONE: 713.313.1127 FAX: 713.313.1049 TABLE

More information

UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2019

UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2019 UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2019 I m proud to be paying taxes in the United States. The only thing is I could be just as proud for half the money. - Arthur Godfrey The hardest

More information

PERSONAL INCOME TAX SYLLABUS Summer 2007 Professor Howard S. Chapman

PERSONAL INCOME TAX SYLLABUS Summer 2007 Professor Howard S. Chapman PERSONAL INCOME TAX SYLLABUS Summer 2007 Professor Howard S. Chapman Einstein calculating taxable income Welcome to the study of personal income tax! I hope you find the course interesting, practical,

More information

UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2018

UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2018 UNIVERSITY OF BALTIMORE SCHOOL OF LAW SPRING SEMESTER, 2018 I m proud to be paying taxes in the United States. The only thing is I could be just as proud for half the money. - Arthur Godfrey The hardest

More information

PERSONAL INCOME TAX SYLLABUS Spring 2008 Professor Howard S. Chapman. Einstein preparing his tax return

PERSONAL INCOME TAX SYLLABUS Spring 2008 Professor Howard S. Chapman. Einstein preparing his tax return PERSONAL INCOME TAX SYLLABUS Spring 2008 Professor Howard S. Chapman Einstein preparing his tax return Welcome to the study of personal income tax. I hope you find the course interesting, useful and (sometimes)

More information

At your request, we have researched whether client American Beef Conglomerate, Inc.

At your request, we have researched whether client American Beef Conglomerate, Inc. MEMORANDUM TO: Senior Partner FROM: LL.M. Team Number DATE: November 6, 2015 SUBJECT: 2015-2016 Law Student Tax Challenge Problem At your request, we have researched whether client American Beef Conglomerate,

More information

FOREIGN TAX I Online Syllabus

FOREIGN TAX I Online Syllabus Professor Lathrope Fall 2016 djlathrope@usfca.edu FOREIGN TAX I Online Syllabus COURSE DESCRIPTION: Foreign Tax I is the introductory class in United States international taxation. Coverage includes the

More information

FEDERAL TAX ACCOUNTING AND TAX TIMING ISSUES. Syllabus

FEDERAL TAX ACCOUNTING AND TAX TIMING ISSUES. Syllabus COURSE DESCRIPTION: Professor Davis G. Yee Fall 2016 (415) 547-3803 dyee5@usfca.edu FEDERAL TAX ACCOUNTING AND TAX TIMING ISSUES Syllabus An examination of the concepts and principles underlying the annual

More information

GOVERNORS STATE UNIVERSITY College of Business and Public Administration Division of Accounting, Finance, Economics, and Information Technology

GOVERNORS STATE UNIVERSITY College of Business and Public Administration Division of Accounting, Finance, Economics, and Information Technology GOVERNORS STATE UNIVERSITY College of Business and Public Administration Division of Accounting, Finance, Economics, and Information Technology College of Business and Public Administration Mission Statement

More information

Corporate Taxation Law 749 D.A. Kahn Materials. Kahn, Kahn and Perris, Principles of Corporate Taxation (West, 2010)

Corporate Taxation Law 749 D.A. Kahn   Materials. Kahn, Kahn and Perris, Principles of Corporate Taxation (West, 2010) Corporate Taxation Law 749 D.A. Kahn Fall 2012 Email: dougkahn@umich.edu Materials The materials required for the course: Kahn, Kahn and Perris, Principles of Corporate Taxation (West, 2010) Selected Federal

More information

(a) Develop the ability to identify major legal issues that arise for non-u.s. taxpayers when determining their U.S. federal income tax liabilities.

(a) Develop the ability to identify major legal issues that arise for non-u.s. taxpayers when determining their U.S. federal income tax liabilities. University of Washington School of Law Autumn, 2018 International Tax I, T515 3 credits Class meets Thursdays 5:00-7:50pm, Room 117 Instructor: William Lu Email: WilliamLu99@gmail.com Phone: 516 567-0370

More information

INCOME TAXATION OF TRUSTS AND ESTATES LAWG GEORGETOWN UNIVERSITY LAW CENTER Fall 2016 Professors Hood and Kirk COURSE SYLLABUS

INCOME TAXATION OF TRUSTS AND ESTATES LAWG GEORGETOWN UNIVERSITY LAW CENTER Fall 2016 Professors Hood and Kirk COURSE SYLLABUS COURSE SYLLABUS TIME/PLACE: 5:45 pm 8:45 pm, Tuesdays and Thursdays September 1 September 27, 2016 Room 109, McDonough Hall 1. Course Description This course covers the principal federal income tax rules

More information

READING ASSIGNMENTS PART V

READING ASSIGNMENTS PART V Federal Income Taxation Professor Kirsch Fall 2016 READING ASSIGNMENTS PART V NOTES: Focus on the Code and Regulation sections listed below (rather than the Code and Regulation sections listed in each

More information

INCOME TAXATION OF TRUSTS AND ESTATES LAWG GEORGETOWN UNIVERSITY LAW CENTER Fall 2014 Professors Hood and Kirk COURSE SYLLABUS

INCOME TAXATION OF TRUSTS AND ESTATES LAWG GEORGETOWN UNIVERSITY LAW CENTER Fall 2014 Professors Hood and Kirk COURSE SYLLABUS COURSE SYLLABUS TIME/PLACE: 5:45 pm 8:45 pm, Tuesdays and Thursdays September 2 September 30, 2014 Room 156, McDonough Hall 1. Course Description This course covers the principal federal income tax rules

More information

TAX MEMORANDUM. CPAs, Clients & Associates. David L. Silverman, Esq. Shirlee Aminoff, Esq. DATE: April 2, Attorney-Client Privilege

TAX MEMORANDUM. CPAs, Clients & Associates. David L. Silverman, Esq. Shirlee Aminoff, Esq. DATE: April 2, Attorney-Client Privilege LAW OFFICES DAVID L. SILVERMAN, J.D., LL.M. 2001 MARCUS AVENUE LAKE SUCCESS, NEW YORK 11042 (516) 466-5900 SILVERMAN, DAVID L. TELECOPIER (516) 437-7292 NYTAXATTY@AOL.COM AMINOFF, SHIRLEE AMINOFFS@GMAIL.COM

More information

TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2007 Professor Wayne M. Gazur

TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2007 Professor Wayne M. Gazur TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2007 Professor Wayne M. Gazur REQUIRED COURSE MATERIALS: 1. Lind, Schwarz, Lathrope, & Rosenberg, Fundamentals

More information

International Tax Update

International Tax Update International Tax Update AMERICAN BAR ASSOCIATION SECTION OF TAXATION 26TH ANNUAL PHILADELPHIA TAX CONFERENCE November 6, 2015 11:20 a.m. 12:35 p.m. International Tax Update The panel will discuss the

More information

LAW Estate and Gift Taxation Mon. & Wed. 12:30 PM to 1:45 PM Fall, 2016 Syllabus

LAW Estate and Gift Taxation Mon. & Wed. 12:30 PM to 1:45 PM Fall, 2016 Syllabus LAW 219-001 Estate and Gift Taxation Mon. & Wed. 12:30 PM to 1:45 PM Fall, 2016 Syllabus Richard S. Chisholm, Esq. 4520 East West Highway Suite 650 Bethesda, Maryland 20814 (301) 986-2200, ext. 104 rchisholm@rewlaw.biz

More information

Choice of Entity. Danny Santucci

Choice of Entity. Danny Santucci Choice of Entity Danny Santucci Table of Contents Chapter 1 Sole Proprietorship... 1 Learning Objectives... 1 Introduction... 1 Advantages... 1 Disadvantages... 1 Formation... 1 Start-Up Expenses... 2

More information

FEDERAL TAX PROCEDURE/PROFESSIONAL RESPONSIBILITY. Syllabus

FEDERAL TAX PROCEDURE/PROFESSIONAL RESPONSIBILITY. Syllabus Professor Davis G. Yee Spring 2017 (415) 547-3803 dyee5@usfca.edu FEDERAL TAX PROCEDURE/PROFESSIONAL RESPONSIBILITY COURSE DESCRIPTION: Syllabus An examination of the fundamental principles of civil federal

More information

Section 168. Accelerated Cost Recovery System

Section 168. Accelerated Cost Recovery System Section 168. Accelerated Cost Recovery System 26 CFR 1.168(a) 1T: Modified accelerated cost recovery system (temporary). T.D. 9115 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 Depreciation

More information

COURSE SYLLABUS TA 321 PRINCIPLES OF INTERNATIONAL TAXATION. Michael Vinson

COURSE SYLLABUS TA 321 PRINCIPLES OF INTERNATIONAL TAXATION. Michael Vinson COURSE SYLLABUS TA 321 PRINCIPLES OF INTERNATIONAL TAXATION Michael Vinson Director, International Tax Certificate Program and The Anne and Jeff Howson Adjunct Professor of Taxation Golden Gate University

More information

Colonial Times... 2 The Post Revolutionary Era... 3 The Civil War... 3 The 16th Amendment... 3 World War I and the 1920s... 5 The Social Security

Colonial Times... 2 The Post Revolutionary Era... 3 The Civil War... 3 The 16th Amendment... 3 World War I and the 1920s... 5 The Social Security Colonial Times... 2 The Post Revolutionary Era... 3 The Civil War... 3 The 16th Amendment... 3 World War I and the 1920s... 5 The Social Security Tax... 5 World War II... 5 Developments after World War

More information

Foreign Contingent Debt; Request for Comments Announcement 99 76

Foreign Contingent Debt; Request for Comments Announcement 99 76 Foreign Contingent Debt; Request for Comments Announcement 99 76 I. Summary. The Department of Treasury ( Treasury ) and the Internal Revenue Service (the Service ) intend, in the near future, to withdraw

More information

FEDERAL TAXATION OF PROPERTY DISPOSITIONS Online Course Syllabus

FEDERAL TAXATION OF PROPERTY DISPOSITIONS Online Course Syllabus COURSE DESCRIPTION: FEDERAL TAXATION OF PROPERTY DISPOSITIONS Online Course Syllabus Professor Lathrope Fall 2016 djlathrope@usfca.edu Federal Taxation of Property Dispositions is a course which examines

More information

US proposed regulations offer much-needed guidance on Section 163(j) business interest expense limitation

US proposed regulations offer much-needed guidance on Section 163(j) business interest expense limitation 30 November 2018 Global Tax Alert US proposed regulations offer much-needed guidance on Section 163(j) business interest expense limitation NEW! EY Tax News Update: Global Edition EY s new Tax News Update:

More information

SUMMARY: This document contains temporary regulations that address transactions

SUMMARY: This document contains temporary regulations that address transactions This document is scheduled to be published in the Federal Register on 04/08/2016 and available online at http://federalregister.gov/a/2016-07300, and on FDsys.gov [4830-01-p] DEPARTMENT OF THE TREASURY

More information

ACC 131 FEDERAL INCOME TAXES

ACC 131 FEDERAL INCOME TAXES ACC 131 FEDERAL INCOME TAXES COURSE DESCRIPTION: Prerequisites: ENG 090and RED 090 or DRE 098; MAT070 or DMA 010, 020, 030, 040; or satisfactory score on placement test Corequisites: None This course provides

More information

IMPORTANT INFORMATION FOR THE LIVE PROGRAM

IMPORTANT INFORMATION FOR THE LIVE PROGRAM FOR LIVE PROGRAM ONLY Partnership Terminations: Mastering Section 708 Filing Short Year Returns, Revisiting Elections, Amortization Opportunities, Basis Adjustments and More WEDNESDAY, JANUARY 25, 2017,

More information

Reg (c)(2) (Aug. 3, 2015) Final Regs. On Tax Year Closure for Deceased Partner (1997 Act Change)

Reg (c)(2) (Aug. 3, 2015) Final Regs. On Tax Year Closure for Deceased Partner (1997 Act Change) Reg. 1.706-1(c)(2) (Aug. 3, 2015) Final Regs. On Tax Year Closure for Deceased Partner (1997 Act Change) 7-45 Reg. 1.706-1(c)(2) first sentence: A partnership taxable year shall close with respect to a

More information

Partnership Tax Professor Holz Spring Semester 2016 Syllabus

Partnership Tax Professor Holz Spring Semester 2016 Syllabus Partnership Tax Professor Holz Spring Semester 2016 Syllabus Required Materials: Richard Lipton, Paul Carman, Charles Fassler, & Walter Schwidetzky, Partnership Taxation (3rd Ed. 2012) Federal Income Tax

More information

HIGHLIGHTS OF SELECTED TAX PROVISIONS INCLUDED WITH THE EMERGENCY ECONOMIC STABILIZATION ACT OF 2008 AND SELECTED IRS COST OF LIVING ADJUSTMENTS

HIGHLIGHTS OF SELECTED TAX PROVISIONS INCLUDED WITH THE EMERGENCY ECONOMIC STABILIZATION ACT OF 2008 AND SELECTED IRS COST OF LIVING ADJUSTMENTS HIGHLIGHTS OF SELECTED TAX PROVISIONS INCLUDED WITH THE EMERGENCY ECONOMIC STABILIZATION ACT OF 2008 AND SELECTED IRS COST OF LIVING ADJUSTMENTS JAMES P. TREBBY ASSOCIATE PROFESSOR OF ACCOUNTING MARQUETTE

More information

63200 Federal Register / Vol. 83, No. 235 / Friday, December 7, 2018 / Proposed Rules

63200 Federal Register / Vol. 83, No. 235 / Friday, December 7, 2018 / Proposed Rules 63200 Federal Register / Vol. 83, No. 235 / Friday, December 7, 2018 / Proposed Rules DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG 105600 18] RIN 1545 BO62 Guidance Related to

More information

DISPOSITIONS OF TANGIBLE PROPERTY

DISPOSITIONS OF TANGIBLE PROPERTY //////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////// SPECIAL REPORT DISPOSITIONS OF TANGIBLE PROPERTY

More information

COMMENTS ON TEMPORARY AND PROPOSED REGULATIONS GOVERNING ALLOCATION OF PARTNERSHIP EXPENDITURES FOR FOREIGN TAXES (T.D. 9121; REG )

COMMENTS ON TEMPORARY AND PROPOSED REGULATIONS GOVERNING ALLOCATION OF PARTNERSHIP EXPENDITURES FOR FOREIGN TAXES (T.D. 9121; REG ) COMMENTS ON TEMPORARY AND PROPOSED REGULATIONS GOVERNING ALLOCATION OF PARTNERSHIP EXPENDITURES FOR FOREIGN TAXES (T.D. 9121; REG-139792-02) The following comments are the individual views of the members

More information

Bankruptcy Questions Answered!

Bankruptcy Questions Answered! Bankruptcy Questions Answered! by ROBERT E. McKENZIE, EA, ATTORNEY 2017 ARNSTEIN & LEHR SUITE 1200 120 SOUTH RIVERSIDE PLAZA CHICAGO, ILLINOIS 60606 (312) 876-7100 REMCKENZIE@ARNSTEIN.COM http://www.mckenzielaw.com

More information

Partnership Taxation. Course Description & Study Guide

Partnership Taxation. Course Description & Study Guide Partnership Taxation Course Description & Study Guide The program will examine tax issues relating to the formation and operation of partnerships. Participants will gain a familiarity with basic areas

More information

Consolidated Return Issues for Buyers and Sellers in M&A Transactions

Consolidated Return Issues for Buyers and Sellers in M&A Transactions Consolidated Return Issues for Buyers and Sellers in M&A Transactions Michael L. Schler In this outline, P represents the parent in the target consolidated group; S is the subsidiary in the target consolidated

More information

Corporate Taxation LAWS 6157/ACCT 6450 Course Syllabus Fall 2011 August 14, 2011 ver.

Corporate Taxation LAWS 6157/ACCT 6450 Course Syllabus Fall 2011 August 14, 2011 ver. LAWS 6157/ACCT 6450 August 14, 2011 ver. Professor Wayne M. Gazur, School of Law Telephone: 303-492-7013 Email: wayne.gazur@colorado.edu Office: Wolf 403 Required Course Materials 1. Federal Income Taxation

More information

COURSE SYLLABUS AND INSTRUCTOR PLAN

COURSE SYLLABUS AND INSTRUCTOR PLAN WACO, TEXAS COURSE SYLLABUS AND INSTRUCTOR PLAN FEDERAL INCOME TAX ANNETTE BIGHAM AN EQUAL OPPORTUNITY INSTITUTION 2014 Spring Course Description: A study of the laws currently implemented by the IRS,

More information

Federal Income Taxation Chapter 15 Capital Cost Recovery

Federal Income Taxation Chapter 15 Capital Cost Recovery Presentation: Federal Income Taxation Chapter 15 Capital Cost Recovery Professors Wells October 24, 2017 Antiques p.870 Richard L. Simon Simon acquired two Tourte bows for $30,000 and $21,000, respectively.

More information

Basis Adjustments for Partnerships and LLCs: Tax Law Challenges Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections

Basis Adjustments for Partnerships and LLCs: Tax Law Challenges Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections Presenting a live 110 minute teleconference with interactive Q&A Basis Adjustments for Partnerships and LLCs: Tax Law Challenges Navigating Complex Basis Rules and Avoiding Pitfalls in Section 754 Elections

More information

Chapter 3 Determining gross income

Chapter 3 Determining gross income Chapter 3 Determining gross income Key concepts Taxable income is the base against which tax rates are applied to compute the taxpayer s tax liability. Taxable income is gross income less allowable deductions.

More information

Federal Income Taxation Syllabus (subject to change) (not including some introductory reading material)

Federal Income Taxation Syllabus (subject to change) (not including some introductory reading material) Federal Income Taxation Syllabus (subject to change) (not including some introductory reading material) Fall 2013 Thursday 5:00 to 7:30 p.m. Room 102 Law 525-3 001 Assoc. Prof. Drennan wdrennan@siu.edu

More information

Anti-Loss Importation & Anti-Loss Duplication Rules Update

Anti-Loss Importation & Anti-Loss Duplication Rules Update Anti-Loss Importation & Anti-Loss Duplication Rules Update Scott M. Levine Partner Jones Day Krishna Vallabhaneni Attorney-Advisor (Tax Legislation) U.S. Department of the Treasury Office of Tax Policy

More information

May 3, 2013 Circulation: 10,956. How to minimize income taxes for estates, trusts and beneficiaries

May 3, 2013 Circulation: 10,956. How to minimize income taxes for estates, trusts and beneficiaries May 3, 2013 Circulation: 10,956 Game Change How to minimize income taxes for estates, trusts and beneficiaries May 3, 2013 Scott Goldberger and John Anzivino On Jan. 1, 2013, the income tax playing field

More information

38 USC NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see

38 USC NB: This unofficial compilation of the U.S. Code is current as of Jan. 4, 2012 (see TITLE 38 - VETERANS BENEFITS PART III - READJUSTMENT AND RELATED BENEFITS CHAPTER 37 - HOUSING AND SMALL BUSINESS LOANS SUBCHAPTER III - ADMINISTRATIVE PROVISIONS 3729. Loan fee (a) Requirement of Fee.

More information

Form 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income

Form 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income FOR LIVE PROGRAM ONLY Form 8865 Reporting of Foreign Partnership Income and Navigating Rules for Allocable Share of Foreign Income THURSDAY, AUGUST 3, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR

More information

The Administration's Tax Reform Targets -- Selected Issues

The Administration's Tax Reform Targets -- Selected Issues College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 2015 The Administration's Tax Reform Targets

More information

SYLLABUS TAXATION OF COMPENSATION Spring Semester 2010 Instructor: David Pittman

SYLLABUS TAXATION OF COMPENSATION Spring Semester 2010 Instructor: David Pittman SYLLABUS TAXATION OF COMPENSATION Spring Semester 2010 Instructor: David Pittman The timing and content of assignments on this syllabus may change as the course progresses. If so, you will be notified

More information

Sole Proprietorship Limited Liability Co. (LLC) C-Corp S-Corp Fairly Easy Fairly Easy Fairly Easy Moderately Difficult

Sole Proprietorship Limited Liability Co. (LLC) C-Corp S-Corp Fairly Easy Fairly Easy Fairly Easy Moderately Difficult Estimated Ease of Formation Fairly Easy Fairly Easy Fairly Easy Moderately Difficult Formation Procedure Key Documents for Formation No Filing Required -DBA Filing (Give the business a name other than

More information

THE REGULATIONS GOVERNING INTERCOMPANY TRANSACTIONS WITHIN CONSOLIDATED GROUPS. August Mark J. Silverman Steptoe & Johnson LLP Washington, D.C.

THE REGULATIONS GOVERNING INTERCOMPANY TRANSACTIONS WITHIN CONSOLIDATED GROUPS. August Mark J. Silverman Steptoe & Johnson LLP Washington, D.C. PRACTISING LAW INSTITUTE TAX STRATEGIES FOR CORPORATE ACQUISITIONS, DISPOSITIONS, SPIN-OFFS, JOINT VENTURES FINANCINGS, REORGANIZATIONS AND RESTRUCTURINGS 2001 THE REGULATIONS GOVERNING INTERCOMPANY TRANSACTIONS

More information

Pearson s Federal Taxation Corporations, Partnerships, Estates & Trusts (2019 edition) Textbook Updates

Pearson s Federal Taxation Corporations, Partnerships, Estates & Trusts (2019 edition) Textbook Updates Pearson s Federal Taxation Corporations, Partnerships, Estates & Trusts (2019 edition) Textbook Updates Several chapters Rev. Proc. 2018-57 Notice 2018-83 Chapter 1 Tax Research Page 32 Table of Updates

More information

Internal Revenue Code Section 529(c)(2)(B) Qualified tuition programs

Internal Revenue Code Section 529(c)(2)(B) Qualified tuition programs Internal Revenue Code Section 529(c)(2)(B) Qualified tuition programs CLICK HERE to return to the home page (a) General rule. A qualified tuition program shall be exempt from taxation under this subtitle.

More information

FEDERAL ESTATE AND GIFT TAXATION Fall Semester 2007 Professor Wayne M. Gazur

FEDERAL ESTATE AND GIFT TAXATION Fall Semester 2007 Professor Wayne M. Gazur FEDERAL ESTATE AND GIFT TAXATION Fall Semester 2007 Professor Wayne M. Gazur Required Materials: Campfield, Dickinson, & Turnier, Taxation of Estates, Gifts and Trusts (23rd Edition, 2006, ThomsonWest

More information

Internal Revenue Code Section 163(h)(2)(D) Interest

Internal Revenue Code Section 163(h)(2)(D) Interest Note: This document has been updated to reflect amendments by the TCJA, Pub. L. No. 115-97. CLICK HERE to return to the home page Internal Revenue Code Section 163(h)(2)(D) Interest (a) General rule. There

More information

Passive Foreign Investment Company Tax Regulations Navigating Complex Tax Features of Foreign Investments Absent Clear IRS Guidance

Passive Foreign Investment Company Tax Regulations Navigating Complex Tax Features of Foreign Investments Absent Clear IRS Guidance presents Passive Foreign Investment Company Tax Regulations Navigating Complex Tax Features of Foreign Investments Absent Clear IRS Guidance A Live 110-Minute Teleconference/Webinar with Interactive ti

More information

TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2005 Professor Wayne M. Gazur

TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2005 Professor Wayne M. Gazur TAXATION OF BUSINESS ENTITIES II Corporate Taxation (Accounting 6450/LAWS 6157) Spring Semester 2005 Professor Wayne M. Gazur REQUIRED COURSE MATERIALS: 1. Lind, Schwarz, Lathrope, & Rosenberg, Fundamentals

More information

and before Jan. 1, 2014, and (2) Reg (e)(2)(ii)(d)(2) ( G ), if the property for which the taxpayer is otherwise changing 42

and before Jan. 1, 2014, and (2) Reg (e)(2)(ii)(d)(2) ( G ), if the property for which the taxpayer is otherwise changing 42 https://checkpoint.riag.com/app/view/toolitem?usid=2beac4h462ac&feature=tcheckpoint&lastcpreqid=6... Page 1 of 10 Checkpoint Contents Federal Library Federal Editorial Materials Federal Tax Coordinator

More information

Introduction to the Taxation of Financial Products Summer 2016 LAWT 992/491 - LL.M --- TaxA 692/185 M.S. --- LAW 992/512 J.D.

Introduction to the Taxation of Financial Products Summer 2016 LAWT 992/491 - LL.M --- TaxA 692/185 M.S. --- LAW 992/512 J.D. Introduction to the Taxation of Financial Products Summer 2016 LAWT 992/491 - LL.M --- TaxA 692/185 M.S. --- LAW 992/512 J.D. Arturo Estrada Email: AEstrada@ubalt.edu "Office" Hours by appointment (703)

More information

Apportionment of Tax Items among the Members of a Controlled Group of Corporations. ACTION: Final regulations and removal of temporary regulations.

Apportionment of Tax Items among the Members of a Controlled Group of Corporations. ACTION: Final regulations and removal of temporary regulations. [4830-01-p] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 9476] RIN 1545-BI62; RIN 1545-BG39 Apportionment of Tax Items among the Members of a Controlled Group of Corporations AGENCY:

More information

Cafeteria Plan. Company Data: Company Information:

Cafeteria Plan. Company Data: Company Information: Cafeteria Plan Company Data: Company Information: 1. Name of adopting employer (Plan Sponsor): 2a. Plan Sponsor address line 1: 2b. Plan Sponsor address line 2: 3. Plan Sponsor city: 4. Plan Sponsor state:

More information

Course Level: Overview. This program is appropriate for professionals at all organizational levels. (24 Credits)

Course Level: Overview. This program is appropriate for professionals at all organizational levels. (24 Credits) Partnership Taxation Course Description & Study Guide The program will examine tax issues relating to the formation and operation of partnerships. Participants will gain a familiarity with basic areas

More information

PARTNERSHIP TAXATION

PARTNERSHIP TAXATION PARTNERSHIP TAXATION February 2016 Update to THIRD EDITION RICHARD M. LIPTON, ESQ. Partner, Baker & McKenzie LLP PAUL CARMAN, ESQ. Partner, Chapman and Cutler LLP CHARLES FASSLER, ESQ. Of Counsel, Bingham

More information

Prototype Non-Standardized Money Purchase

Prototype Non-Standardized Money Purchase Prototype Non-Standardized Money Purchase Company Data: Company Information: 1. Name of adopting employer (Plan Sponsor): 2a. Plan Sponsor address line 1: 2b. Plan Sponsor address line 2: 3. Plan Sponsor

More information

Information Reporting and Civil Penalties (in a Nutshell)

Information Reporting and Civil Penalties (in a Nutshell) I. In General Information Reporting and Civil Penalties (in a Nutshell) By Lucy S. Lee, Esq. Caplin & Drysdale, Chartered Washington, D.C. 2008 Lucy S. Lee The Internal Revenue Code (the Code ) 1 generally

More information

Current. Law. A partnership interest other than a capital interest. Rev Proc IRS Administrative Concession For Vested Profits Only Interest

Current. Law. A partnership interest other than a capital interest. Rev Proc IRS Administrative Concession For Vested Profits Only Interest Current 5-1 Law Sections 83 and 721; Rev Procs 93-27 & 2001-43 1 Rev Proc 93-27 IRS Administrative Concession For Vested Profits Only Interest 5-6 2 Rev Proc 93-27 5-6 Profits Interest Profits Intererst

More information

ACTION: Notice of proposed rulemaking and notice of public. SUMMARY: This document contains proposed regulations on the tax

ACTION: Notice of proposed rulemaking and notice of public. SUMMARY: This document contains proposed regulations on the tax [4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [REG-111119-99] RIN 1545-AX32 Partnership Mergers and Divisions AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice

More information

NEW YORK STATE BAR ASSOCIATION TAX SECTION REPORT ON FDIC-ASSISTED TAXABLE ACQUISITIONS

NEW YORK STATE BAR ASSOCIATION TAX SECTION REPORT ON FDIC-ASSISTED TAXABLE ACQUISITIONS NEW YORK STATE BAR ASSOCIATION TAX SECTION REPORT ON FDIC-ASSISTED TAXABLE ACQUISITIONS April 30, 2010 Report No. 1210 New York State Bar Association Tax Section Report on FDIC-Assisted Taxable Acquisitions

More information

Deemed Distributions Under Section 305(c) of Stock and Rights to Acquire Stock. SUMMARY: This document contains proposed regulations regarding deemed

Deemed Distributions Under Section 305(c) of Stock and Rights to Acquire Stock. SUMMARY: This document contains proposed regulations regarding deemed This document is scheduled to be published in the Federal Register on 04/13/2016 and available online at http://federalregister.gov/a/2016-08248, and on FDsys.gov [4830-01-p] DEPARTMENT OF THE TREASURY

More information

HEDGING TRANSACTIONS: TAX TREATMENTS

HEDGING TRANSACTIONS: TAX TREATMENTS HEDGING TRANSACTIONS: TAX TREATMENTS WHAT IS A HEDGE? Hedging transaction means any transaction entered into by the taxpayer in the normal course of the taxpayer s trade or business primarily to manage

More information

THE CORPORATE INCOME TAX

THE CORPORATE INCOME TAX 3 C H A P T E R THE CORPORATE INCOME TAX LEARNING OBJECTIVES After studying this chapter, you should be able to 1 Apply the requirements for selecting tax years and accounting methods to various types

More information

FINAL REGULATIONS REGARDING CAPITALIZATION OF EXPENDITURES RELATING TO INTANGIBLE S

FINAL REGULATIONS REGARDING CAPITALIZATION OF EXPENDITURES RELATING TO INTANGIBLE S FINAL REGULATIONS REGARDING CAPITALIZATION OF EXPENDITURES RELATING TO INTANGIBLE S March 1, 2004 The IRS issued final regulations on December 31, 2003, which further clarify whether expenditures incurred

More information

1111 Constitution Avenue, NW 1111 Constitution Avenue, NW Washington, DC Washington, DC 20224

1111 Constitution Avenue, NW 1111 Constitution Avenue, NW Washington, DC Washington, DC 20224 The Honorable John A. Koskinen Commissioner Chief Counsel Internal Revenue Service Internal Revenue Service 1111 Constitution Avenue, NW 1111 Constitution Avenue, NW Washington, DC 20224 Washington, DC

More information

COURSE SYLLABUS AND INSTRUCTOR PLAN

COURSE SYLLABUS AND INSTRUCTOR PLAN WACO, TEXAS COURSE SYLLABUS AND INSTRUCTOR PLAN FEDERAL INCOME TAX ANNETTE BIGHAM AN EQUAL OPPORTUNITY INSTITUTION SPRING 2015 Course Description: A study of the laws currently implemented by the IRS,

More information

CORPORATE INCOME TAX II. Course Syllabus Spring 2017

CORPORATE INCOME TAX II. Course Syllabus Spring 2017 CORPORATE INCOME TAX II Course Syllabus Spring 2017 Class I Class II Course introduction and administrative matters Overview of statutory reorganization provisions Judicial doctrines: continuity of interest

More information

International Tax Update

International Tax Update International Tax Update Stephen Bates Jose Murillo Cynthia Yu 3 May 2016 Disclaimers This presentation is provided solely for the purpose of enhancing knowledge on tax matters. It does not provide tax

More information

LIST OF SUBSTANTIVE CHANGES AND ADDITIONS. PPC s Guide to Real Estate Taxation. Twenty-fourth Edition (June 2018)

LIST OF SUBSTANTIVE CHANGES AND ADDITIONS. PPC s Guide to Real Estate Taxation. Twenty-fourth Edition (June 2018) Route To: j Partners j Managers j Staff j File LIST OF SUBSTANTIVE CHANGES AND ADDITIONS PPC s Guide to Real Estate Taxation Twenty-fourth Edition (June 2018) Highlights of this Edition The following are

More information

11/3/2011. Debt & Taxes

11/3/2011. Debt & Taxes Debt & Taxes Elizabeth A. Maresca Clinical Associate Professor Fordham Law School, New York, NY Tax & Consumer Litigation Clinic I. General Rules: Income from discharge of indebtedness, exemptions and

More information

Impact of Tax Reform on Farmers. Tax and Accounting Department Fall 2018

Impact of Tax Reform on Farmers. Tax and Accounting Department Fall 2018 Impact of Tax Reform on Farmers Tax and Accounting Department Fall 2018 Agenda Summary of Tax Reform Individual Business Tax Planning with Business Structure Important Items on a Farm Tax Return Disclaimer

More information

Taxation of Individual Income

Taxation of Individual Income Taxation of Individual Income ELEVENTH EDITION SPRING 2018 SUPPLEMENT Addressing changes resulting from the 2017 tax legislation J. Martin Burke Michael K. Friel CAROLINA ACADEMIC PRESS Durham, North Carolina

More information

LIST OF SUBSTANTIVE CHANGES AND ADDITIONS. PPC s 1065 Deskbook. Twenty-ninth Edition (October 2018)

LIST OF SUBSTANTIVE CHANGES AND ADDITIONS. PPC s 1065 Deskbook. Twenty-ninth Edition (October 2018) Route To: Partners Managers Staff File LIST OF SUBSTANTIVE CHANGES AND ADDITIONS PPC s 1065 Deskbook Twenty-ninth Edition (October 2018) Highlights of this Edition The following are some of the important

More information

Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs]

Certain Transfers of Property to Regulated Investment Companies [RICs] and Real Estate Investment Trusts [REITs] [4830-01-p] Published March 18, 2003 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 602 [TD 9047] RIN 1545-BA36 and 1545-AW92 Certain Transfers of Property to Regulated Investment

More information

IRS Issues Proposed Regulations on BEAT

IRS Issues Proposed Regulations on BEAT The Proposed BEAT Regulations Provide New Guidance on Significant Aspects of BEAT That Were Not Addressed in the Statute, but Leave Some Questions Unanswered SUMMARY On December 13, 2018, the Internal

More information

CHAPTER 10 COMPARATIVE FORMS OF DOING BUSINESS LECTURE NOTES

CHAPTER 10 COMPARATIVE FORMS OF DOING BUSINESS LECTURE NOTES CHAPTER 10 COMPARATIVE FORMS OF DOING BUSINESS 10.1 FORMS OF DOING BUSINESS LECTURE NOTES 1. Legal Forms. Business entities can be organized into the following principal legal forms. Sole proprietorship.

More information

General Rule Capital Gain or Loss. Sec Example 12-1 Sale. General rule: a sale by a partner generates capital gain or loss.

General Rule Capital Gain or Loss. Sec Example 12-1 Sale. General rule: a sale by a partner generates capital gain or loss. General Rule Capital Gain or Loss Sec. 741 12-3 1 General rule: a sale by a partner generates capital gain or loss. Exception for seller s share of partnership hot asset gains or losses. Same for: Sale

More information

Corporate Taxation Chapter Two: Corporate Formation

Corporate Taxation Chapter Two: Corporate Formation Presentation: Corporate Taxation Chapter Two: Corporate Formation Professors Wells January 21, 2015 Key Statutory Provision: 351, 357, 358, 362, 368(c), 1032, 1223(1), 1223(2), 1245(b)(3), 118, 195, 212(3),

More information

New York State Bar Association Tax Section

New York State Bar Association Tax Section Report No. 1350 New York State Bar Association Tax Section Report on Proposed and Temporary Regulations on United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships

More information

Recent Developments in Corporate Tax

Recent Developments in Corporate Tax Recent Developments in Corporate Tax Scott M. Levine Jones Day Washington D.C. Lori A. Hellkamp Jones Day Washington D.C. Todd R. Miller Jones Day Detroit Tax Executives Institute Dearborn, Michigan October

More information

Centralized Partnership Audit Regime: Adjusting Tax Attributes. SUMMARY: This document contains proposed regulations implementing section 1101

Centralized Partnership Audit Regime: Adjusting Tax Attributes. SUMMARY: This document contains proposed regulations implementing section 1101 This document is scheduled to be published in the Federal Register on 02/02/2018 and available online at https://federalregister.gov/d/2018-01989, and on FDsys.gov 4830-01-p DEPARTMENT OF THE TREASURY

More information

CHAPTER 10 ACQUISITIVE REORGANIZATIONS. Problems, pages

CHAPTER 10 ACQUISITIVE REORGANIZATIONS. Problems, pages CHAPTER 10 ACQUISITIVE REORGANIZATIONS Problems, pages 355-356 10-1 Treas. Reg. 1.368-1(e) does not directly change the result in Kass. The problem in Kass was that the acquiring corporation used cash

More information

Redemptions of Partnership Interests and Divisions of Partnerships

Redemptions of Partnership Interests and Divisions of Partnerships College of William & Mary Law School William & Mary Law School Scholarship Repository William & Mary Annual Tax Conference Conferences, Events, and Lectures 2006 Redemptions of Partnership Interests and

More information

June 5, Mr. Daniel I. Werfel Acting Commissioner Internal Revenue Service 1111 Constitution Avenue, Room 3000 Washington, DC 20024

June 5, Mr. Daniel I. Werfel Acting Commissioner Internal Revenue Service 1111 Constitution Avenue, Room 3000 Washington, DC 20024 June 5, 2013 Mr. Daniel I. Werfel Acting Commissioner Internal Revenue Service 1111 Constitution Avenue, Room 3000 Washington, DC 20024 Re: Comments on Revenue Ruling 99-5 Dear Mr. Werfel: The American

More information

Client Alert February 14, 2019

Client Alert February 14, 2019 Tax News and Developments North America Client Alert February 14, 2019 Voluminous Proposed Regulations Interpret Section 163(j) Overview On November 26, 2018, the Treasury and IRS released proposed regulations

More information

GEORGE MASON UNIVERSITY SCHOOL OF LAW. CORPORATE TAX Course Number: Credit Hours. Spring 2015 Tuesday 6:00-8:40 p.m.

GEORGE MASON UNIVERSITY SCHOOL OF LAW. CORPORATE TAX Course Number: Credit Hours. Spring 2015 Tuesday 6:00-8:40 p.m. GEORGE MASON UNIVERSITY SCHOOL OF LAW CORPORATE TAX Course Number: 198-002 3 Credit Hours Spring 2015 Tuesday 6:00-8:40 p.m. Hazel Hall Professor Sean W. Mullaney sean.w.mullaney@us.pwc.com 202.495.9545

More information

International Income Taxation Chapter 10

International Income Taxation Chapter 10 Presentation: International Income Taxation Chapter 10 Professor Wells March 29, 2012 Overview of 367 Tax-free treatment under the Subchapter C rules 367(a): Governs transfer of appreciated property by

More information

CHAPTER 18 SECTION 199A 1 TABLE OF CONTENTS Introduction to the Section 199A Deduction... 1

CHAPTER 18 SECTION 199A 1 TABLE OF CONTENTS Introduction to the Section 199A Deduction... 1 CHAPTER 18 SECTION 199A 1 TABLE OF CONTENTS 18.1 Introduction to the Section 199A Deduction... 1 18.2 Ancillary Consequences of Section 199A Deduction... 3 18.2.1 Ancillary Items Impacted by Section 199A

More information

IRS tax reporting changes for investors

IRS tax reporting changes for investors IRS tax reporting changes for investors E*TRADE Financial Corporation and its affiliates do not provide tax advice, and you always should consult your own tax advisor regarding your personal circumstances

More information

(a) Scope. This section provides rules for general asset accounts under section 168(i)(4). The

(a) Scope. This section provides rules for general asset accounts under section 168(i)(4). The Checkpoint Contents Federal Library Federal Source Materials Code, Regulations, Committee Reports & Tax Treaties Final, Temporary, Proposed Regulations & Preambles Final, Temporary & Proposed Regulations

More information