The 5th Edition explores the federal income taxation of corporations and their shareholders and can be used in a variety of courses covering corporate taxation at either the J.D. or LL.M. level. Numerous important revisions to the statutory structure over the past few decades-the changing magnitude of the capital gain preference, the preferential rate for dividends, the 2017 reduction to the corporate tax rate, a maximum individual rate now substantially higher than the maximum corporate rate, and repeal of the General Utilities rule providing nonrecognition of gain upon the distribution of property by a corporation-have changed dramatically the important issues. Most chapters and sections of chapters are introduced by a textual discussion or outline of the basic issues and structure of the statute governing treatment of the particular item or transaction covered in the chapter or section. This is followed by a principal case reading, generally a judicial decision but sometimes an IRS ruling or legislative history excerpt. A Detailed Analysis follows the principal case reading and is intended to facilitate the professor's ability to tailor the class to the needs of a particular course through selecting portions of that analysis. Class Discussion Problems are incorporated directly into the text. In selecting and organizing the materials, we have attempted to maximize the usefulness of these materials for whatever approach the professor wishes to adopt-an intensive technical analysis, a problem-oriented method, a consideration of the policies that underlie the technical tax structure, or a survey of the principal elements of the federal income taxation of corporations.

This casebook explores both the technical and policy issues associated with general principles of income taxation. The book is unrivaled in scope, depth of analysis, and flexibility. The materials facilitate focusing on either in depth coverage or broad policy issues for any particular topic. Within units, the material moves from the straight-forward to more complex rules, thus enabling each professor to make a decision as to the level of complexity which he or she wishes to reach in the course. The text can be used in a single course covering basic income taxation or a sequence of courses dealing with income taxation at either the J.D. or LL.M. level.

This book explores the technical and policy issues associated with partnership and S corporation taxation. This book is suitable for courses on Subchapter K and Subchapter S taxation at either the J.D. or LL.M. level. Its organization allows for flexibility to suit the individual instructor's choice of method and scope of coverage. The 6th Edition includes recent statutory and regulatory changes, including those relating to the Tax Cuts and Jobs Act, and discusses significant judicial decisions affecting the federal income taxation of partnerships and S corporations. Discussion Problem Sets are incorporated directly into the text. In selecting and organizing the materials, the book maximizes the usefulness of these materials for whatever approach the professor wishes to adopt-an intensive technical analysis, a problem-oriented method, a consideration of the policies that underlie the technical tax structure, or a survey of the principal elements of the federal income taxation of partnerships and S corporations.

This helpful study aid addresses the international taxation aspects of the U.S. tax system. In recent years, there has been an effort among the G-7 nations to better align their domestic tax laws. As a result, principles and enforcement mechanisms found in the U.S. tax system increasingly may resemble those of other nations. However, even though there may be similarities in the design of the tax laws of different nations, ultimately the study of international taxation represents a study of the laws of a particular nation. Thus, this book focuses on the study of U.S. taxation as applied to economic activity with an international element. The Fifth Edition is divided into three sections: common elements of international taxation for both inbound and outbound taxation, inbound U.S. taxation, and outbound U.S. taxation. Special attention is focused on base erosion and profit shifting strategies and the resulting complexity that has been added to the U.S. tax regime to address this phenomenon in the inbound and outbound context. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.

The 6th Edition, like earlier editions, explores in depth in a single volume both the technical and policy issues associated with the taxation of partnerships, C corporations, and S corporations. It is adaptable for use in a wide variety of courses or sequence of courses dealing with taxation of business organizations at either the J.D. or LL.M. level. The 6th Edition includes recent statutory and regulatory changes, including those relating to the Tax Cuts and Jobs Act, and discusses significant judicial decisions affecting the federal income taxation of partnerships, C corporations, and S corporations. Discussion Problem Sets are incorporated directly into the text. In selecting and organizing the materials, the book maximizes the usefulness of these materials for whatever approach the professor wishes to adopt-an intensive technical analysis, a problem-oriented method, a consideration of the policies that underlie the technical tax structure, or a survey of the principal elements of the federal income taxation of partnerships, C corporations, and S corporations.

This casebook explores both the technical and policy issues associated with general principles of income taxation. The book is unrivaled in scope, depth of analysis, and flexibility. The materials facilitate focusing on either in depth coverage or broad policy issues for any particular topic. Within units, the material moves from the straight-forward to more complex rules, thus enabling each professor to make a decision as to the level of complexity which he or she wishes to reach in the course. The text can be used in a single course covering basic income taxation or a sequence of courses dealing with income taxation at either the J.D. or LL.M. level.