The Attribution Rules examines the rules governing situations in which an individual or entity will be deemed to own stock held by another for purposes of various tax rules.

Income Taxation of Life Insurance and Annuity Contracts , considers the federal income tax rules applicable to life insurance and annuity contracts, addressing, for example, the exclusion from gross...

This Portfolio provides a basic reference tool for determining the first-year expensing and additional depreciation deductions available for selected properties.

Description Reductions in Force , written by Kathy Davidson Ireland, Esq., Bethesda, Maryland, analyzes the numerous laws that apply to an employer that wishes to implement voluntary or...

Description   Exclusion of Scholarships and Other Receipts for Educational Expenses addresses several important income tax issues relating to educational costs. The first section of this...

Corporate Bankruptcy — Special Topics looks at certain unique tax issues that may arise in connection with a bankruptcy.

This Portfolio focuses its discussion on the “sale or exchange” requirement that is necessary in order for a capital asset to qualify for capital asset treatment under §1221; the interpretation of the “property” requirement under §1221; alternative characterizations of sales or exchanges of capital assets under other Code sections; various judicial doctrines that may recharacterize gains or losses as arising or not arising, as applicable, from the sale or exchange of a capital asset; specific issues involved in the sale of a business; the computation and character of a capital gain or loss; and issues related to the treatment of gain from the sale or exchange of qualified small business stock held by a noncorporate taxpayer for more than five years.

This Portfolio discusses the scope of discovery and the discovery tools available to a taxpayer in the context of civil tax litigation in the federal district courts, the U.S. Tax Court, and the U.S. Court of Federal Claims.

Boot Distributions and Assumption of Liabilities discusses the tax problems arising in connection with boot distributions by a corporation to shareholders and creditors.

This Portfolio focuses on the provisions applicable to federal income tax withholding, Medicare, Social Security, unemployment taxes, and self-employment tax and reporting.

This Portfolio analyzes the business, tax, and legal considerations of self-insuring or self-funding group employee benefits, such as life, sick, accident, and other similar benefits.

This Portfolio analyzes the accounting method changes regarding uniform capitalization rules and the application of the rules in the international context and in various industries.

This Portfolio analyzes the cost capitalization rules applicable to manufactured inventories, inventories of wholesalers and retailers, self-constructed assets, and for-sale property.

This Portfolio explains the fundamentals of federal tax research, including the legislative, administrative, and judicial authorities that tax practitioners deal.

This Portfolio explains the substantive and procedural rules for deducting travel, transportation, and commuting expenses and analyzes the problems that arise with self-employment.

Transfers to Controlled Corporations: Related Problems discusses the relationship between §351 and other provisions of the Code.

Transfers to Controlled Corporations: In General discusses the tax considerations of transferring property to corporations controlled by the transferors.

Transferee Liability analyzes the application of §6901 and related judicial interpretations.

 

This Portfolio analyzes the tax consequences of transactions involving a variety of financial instruments and products and describes operations- and tax-related issues.

This Portfolio analyzes the deductions allowable for taxpayers carrying on a trade or business or a for-profit activity.

This Portfolio examines the requirements that trade and professional associations must meet in order to secure and maintain tax-exempt status.

This Portfolio examines the tax treatment of debt-instrument issuers and holders under §§1271 and reviews the original issue discount rules and Treasury regulations interpreting them.

Timber Transactions analyzes the special tax treatment of timber operations, including changes made by the American Jobs Creation Act of 2004.

This Portfolio analyzes the income tax consequences of the mark-to-market rules of §475 for securities and commodities held by dealers and traders.

This Portfolio analyzes the rules regarding credits against income tax on a portion of the price of selected productive assets and their use in determining cost segregation of assets.

This Portfolio analyzes the economic substance doctrine and associated judicial anti-abuse doctrines.

Tax-Free Exchanges Under Section 1031 analyzes the nontaxable exchange provisions of §1031 of the Internal Revenue Code.

Tax-Deferred Annuities — Section 403(b) examines tax-deferred annuities governed by Code §403(b).

This Portfolio discusses §§851 through 855, 860, and 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies and the tax issues of mutual funds.

This Portfolio examines the tax consequences of various real estate transactions, providing a practical working tool for attorneys, accountants, investors, and syndicators.

This Portfolio analyzes the tax consequences of transactions involving equity derivatives ranging from “traditional” equity derivatives to more “modern” equity derivatives.

Taxation of Cooperatives and Their Patrons analyzes the federal income tax treatment of cooperatives and patrons. 

Tax Shelters discusses the rules, analyzes the goals of certain tax products, examines regulations and IRS guidance, and provides a method of evaluating corporate tax shelter products.

Tax Planning Patents examines many aspects of the tax planning patent phenomenon and the practical issues faced by tax practitioners.

This Portfolio discusses the tax implications of developing and licensing patents and know-how.

This Portfolio reviews, analyzes, and makes tax planning suggestions regarding the creation, licensing, and sale of these intangible assets.

This Portfolio analyzes various topics regarding taxation and legal issues that confront educational organizations.

This Portfolio, Tax Incentives to Hire, Retain, or Compensate Employees, brings together in one place analyses of the many income tax provisions designed to encourage employers to hire employees and to retain those employees.

This Portfolio analyzes of the many income tax provisions designed to encourage production of energy resources and conservation of energy and other natural resources.

This Portfolio brings together in one place analysis of the many income tax provisions designed to encourage business activity and investment in economically distressed areas.

This Portfolio discusses the tax rules and tax consequences that apply to home ownership, home sales, and owner relocations.

Tax Crimes discusses the area of individual and corporate criminal tax liability.

This Portfolio provides a conceptual framework for handling credit issues and explores the nature, scope, significance, definition, and fundamental concepts of credits.

Tax Court Litigation discusses the issues raised when a case is initiated and tried before the United States Tax Court.

This Portfolio examines the tax consequences to payor and payee following a settlement or judgment and analyzes the tax issues of personal injury and non-personal injury lawsuits.

This Portfolio analyzes the tax implications when a business chooses to restructure its debts as an alternative to foreclosure or bankruptcy.

Tax Aspects of Franchising discusses the legal environment and history of franchising in the United States before analyzing the tax and legal aspects of franchising.

Structuring Real Estate Joint Ventures with Private REITs addresses how the goals of investors are achieved by entering into joint ventures using non-publicly traded or “private” REITs.

This Portfolio discusses the principal tax planning considerations related to designing an appropriate transactional structure for a corporate acquisition.

This Portfolio discusses the tax rules governing the sale of stock of a parent corporation to its subsidiary and of stock of one corporation to a sister corporation.

Stock Rights and Stock Dividends—Sections 305 and 306 analyzes the tax problems that arise in connection with dividend distributions of common or preferred stock and stock rights.

This Portfolio analyzes in detail the elections under §338(g) and §338(h)(10), available when a purchasing corporation makes a “qualified stock purchase” of a target corporation.

This Portfolio details the structure, the tax rules, and requirements for establishing incentive stock options and employee stock purchase plans.

This Portfolio analyzes the deduction of state, local, and federal taxes, and the timing of the deduction, with primary focus on §§164, 275, and 461 in the Internal Revenue Code.

State Taxation of Mergers and Acquisitions analyzes the state and local tax implications of mergers and acquisitions by corporate multistate taxpayers.

State Taxation of Compensation and Benefits focuses on the impact of state taxation on executive and employee compensation.

Start-Up Expenditures analyzes in depth the tax treatment of start-up expenses under §195 of the Internal Revenue Code of 1986.

This Portfolio discusses different types of retirement plans, including alternative or hybrid plan designs, and discusses the universe of defined benefit pension plans.

Small Business Corporation Stock: Special Tax Incentives describes a number of Code provisions providing special incentives to invest in small businesses.

This Portfolio analyzes the tax consequences of single-company reorganizations: recapitalization under §368(a)(1)(E) and a change in identity, form, or place under §368(a)(1)(F).

SEPs and SIMPLEs analyzes the rules that apply to simplified employee pensions (SEPs) and savings incentive match plans for employees (SIMPLE plans).

This Portfolio examines registration requirements under federal securities laws, reporting requirements, the short-swing profits recovery rules, and tender offer requirements.

This Portfolio examines rules regarding allocation methods under §482 and addresses other particular issues, such as correlative allocations, the burden of proof, and penalties.

 

This Portfolio examines judicial decisions and IRS practice involving the interpretation and application of §482 and its regulations to transactions between U.S. controlled taxpayers.

This Portfolio discusses the tax considerations when a taxpayer adopts, or changes to, a particular taxable year and examines the regulations covering those selections and changes.

This Portfolio discusses the deduction available to taxpayers who engage in qualifying domestic production activities, including the formula for computing the deduction.

 

This Portfolio contains a detailed analysis and discussion of the income tax treatment of educational and related expenses, including scholarships and fellowship grants.

S Corporations: Operations reviews the special tax status of S corporations, including S corporation shareholders, who are taxed pro rata on the corporation's income.

S Corporations: Formation and Termination reviews the rules regarding the formation and termination of S corporations.

This Portfolio examines the operation of Internal Revenue Code §83 in taxing various types of transfers of property in connection with the performance of services by employees.

This Portfolio discusses the liability of responsible persons under §6672 and of lenders and others who provide funds under §3505.

Research and Development Expenditures analyzes the tax treatment of research and development expenditures.

Reporting Farm Income describes the tax accounting periods and methods available to farmers and ranchers in determining their federal tax liability.

This Portfolio examines the reporting and disclosure requirements imposed by ERISA on administrators of employee benefit plans and the types of plans subject to ERISA's requirements.

This Portfolio provides an in-depth discussion of the reportable transaction rules under Regs. §1.6011-4 as well as the associated penalties for noncompliance.