Read e-book online South-Western Federal Taxation: Comprehensive Volume 2014 PDF

By William H. Hoffman, William A. Raabe, James E. Smith, David M. Maloney

Solid reference for tax execs.

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Additional info for South-Western Federal Taxation: Comprehensive Volume 2014 Edition

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May not be copied, scanned, or duplicated, in whole or in part. Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s). Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it. S. Taxation Tax in the News: So Long, It’s Been Nice Knowing You 25-1 TAX PLANNING xxxvii 25-35 25-36 25-36 The Big Picture: Going International 25-1 OVERVIEW OF INTERNATIONAL TAXATION 25-2 Global Tax Issues: Other Countries’ Taxes Can Be Strange, Too 25-4 TAX TREATIES 25-4 Planning under Subpart F 25-38 Financial Disclosure Insights: Effective Tax Strategies Using Overseas Operations 25-5 Using the Check-the-Box Regulations Transferring Intangible Assets Offshore 25-38 25-38 Transfer Pricing 25-39 SOURCING OF INCOME AND DEDUCTIONS 25-5 Refocus on the The Big Picture: Going International 25-39 Income Sourced inside the United States 25-6 Global Tax Issues: Why the Treaty Process Stalls 25-7 Tax in the News: Sourcing Income in Cyberspace Income Sourced outside the United States 25-9 25-9 CHAPTER 26 TAX PRACTICE AND ETHICS 26-1 25-9 The Big Picture: A Tax Adviser’s Dilemma 26-1 TAX ADMINISTRATION 26-2 Allocation and Apportionment of Deductions Transfer Pricing Ethics & Equity: The Costs of Good Tax Planning FOREIGN CURRENCY TRANSACTIONS Tax in the News: APAs Reduce Uncertainty in Transfer Pricing Disputes Concept Summary: Recognition of Foreign Exchange Gain or Loss Tax Issues 25-10 25-11 25-12 25-13 25-14 25-14 The Foreign Tax Credit Limitation and Sourcing Provisions Financial Disclosure Insights: Deferred Tax Assets Overseas The Foreign Corporation as a Tax Shelter 25-36 25-37 25-38 Tax in the News: How Big Is the Tax Gap?

Due to electronic rights, some third party content may be suppressed from the eBook and/or eChapter(s). Editorial review has deemed that any suppressed content does not materially affect the overall learning experience. Cengage Learning reserves the right to remove additional content at any time if subsequent rights restrictions require it. Contents xxxv FORMATION OF A PARTNERSHIP: TAX EFFECTS 21-6 CHOICE OF BUSINESS ENTITY 22-2 Contributions to the Partnership 21-6 An Overview of S Corporations 22-2 Exceptions to the General Rule of § 721 Other Issues Relative to Property Contributed under § 721 21-7 21-9 Concept Summary: Making an S Election Decision 22-3 Concept Summary: Partnership Formation and Initial Basis Computations Tax Accounting Elections QUALIFYING FOR S CORPORATION STATUS 22-3 21-12 21-12 Definition of a Small Business Corporation Tax in the News: S Corporations by the Numbers 22-3 22-4 Initial Costs of a Partnership 21-13 Tax in the News: S Corporation Lottery Wins Taxed 22-5 Method of Accounting Taxable Year of the Partnership 21-14 21-15 Making the Election Shareholder Consent 22-7 22-8 Loss of the Election 22-9 OPERATIONS OF THE PARTNERSHIP Measuring and Reporting Partnership Income 21-17 21-17 OPERATIONAL RULES 22-11 Computation of Taxable Income 22-11 Allocation of Income and Loss Tax Treatment of Distributions to Shareholders 22-13 22-14 Global Tax Issues: Various Withholding Procedures Applicable to Foreign Partners 21-21 Partner Allocations and Reporting 21-21 Partner’s Basis Concept Summary: Tax Reporting of Partnership Items Partner’s Capital Account 21-24 Concept Summary: Classification Procedures for Distributions from an S Corporation 22-15 21-25 21-31 Ethics & Equity: Avoiding Schedule M–3 22-18 Loss Limitations 21-31 Concept Summary: Consequences of Noncash Property Distributions 22-19 TRANSACTIONS BETWEEN PARTNERS AND PARTNERSHIPS 21-34 Guaranteed Payments 21-34 Self-Employment Tax and § 1411 Tax of Partners Other Transactions between Partners and Partnerships 21-35 21-37 DISTRIBUTIONS FROM THE PARTNERSHIP 21-38 Proportionate Nonliquidating Distributions 21-39 Proportionate Liquidating Distributions Concept Summary: Proportionate Nonliquidating Distributions (General Rules) 21-42 Tax Treatment of Noncash Property Distributions by the Corporation 22-19 Shareholder’s Basis 22-20 Treatment of Losses Tax on Pre-Election Built-In Gain 22-22 22-25 Passive Investment Income Penalty Tax 22-26 Concept Summary: Calculation of the Built-In Gains Tax Liability 22-27 Other Operational Rules Tax in the News: The Self-Employment Income Advantage General Rules Effect of Hot Assets LIMITED LIABILITY ENTITIES 21-45 21-45 21-46 21-47 Limited Liability Companies 21-47 Tax in the News: Converting a C or S Corporation to a Partnership Entity 21-48 Limited Liability Partnerships 21-48 TAX PLANNING 21-49 Choosing Partnership Taxation 21-49 Formation and Operation of a Partnership Concept Summary: Advantages and Disadvantages of the Partnership Form Basis Considerations and Loss Deduction Limitations 21-49 Transactions between Partners and Partnerships 21-51 Drafting the Partnership Agreement Refocus on the The Big Picture: Why Use a Partnership, Anyway?

As circumstances change, so does the tax result. Consider, for example, what happens when an investor becomes a dealer— capital gains and losses on the disposition of property now convert to ordinary income and losses. Or consider an employee who becomes self-employed—the safe harbor of withholdings is lost, and new quarterly payments on income and selfemployment taxes must be made. Even the purchase of a home can result in significant change—new mortgage interest and property tax deductions cause the standard deduction to be replaced by itemization on Schedule A.

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