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BUSINESS TAXATION DESKBOOK
CORPORATIONS , PARTNERSHIPS , SUBCHAPTER S , AND INTERNATIONAL
Samuel C . Thompson , Jr . ( Center for the Study of Mergers and Acquisitions , Penn State Law , Pennsylvania State University )
This Deskbook surveys the IRC business tax considerations companies should consider in light of the TCAJA . It contains the insights of a longtime mergers and acquisitions professor who has testified on tax policy before Congress and practiced at notable U . S . and international agencies .
Corporate stakeholders and the practitioners who advise them can access digestible overviews of complex TCAJA and state law tax principles . They will also find easy-to-follow reference material on cross-border transactions , deductions , choice of form and entity decisions , mergers and acquisitions , foreign tax treaties , foreign investments , and more . In addition , readers can access tailored pointers for S Corporations , C Corporations , and partnerships .
Stay current with emerging business taxation developments with PLI ’ s Upkeep Service .
2 looseleaf volumes , 1,502 pages , $ 738 , Item # 241254 , ISBN 978-1-4024-3117-3 , Updated annually or as needed
CONTENTS
VOLUME 1 PART I : INTRODUCTION AND TCAJA 1 Introduction and General Principles 2 The TCAJA ’ s Deduction for Certain Pass-Through Income of Individuals , Section 199A
3 The TCAJA ’ s Limitation on the Deduction for Business Interest : Section 163 ( j ): A “ First-Take ” 4 Other Domestic Business-Related
Provisions of the TCAJA
5 Introduction to the International Provisions of the TCAJA : “ The Cookie , the Carrot , and the Four Sticks ”
6 The TCAJA ’ s Impact on the Choice of Form ( or Entity ) Decision for Domestic and Foreign Operations : A “ First Take ”
7 A “ First Take ” on the Impact of the TCAJA on Domestic and Cross-Border M & A
PART II : C CORPORATIONS
8 Organization of C Corporations , Including Debt-Equity Capitalization Issues Under the TCAJA 9 Operation and Liquidation of C Corporations , Including Introduction to Consolidated Return Issues
10 Taxable Acquisition of the Stock or Assets of a C Corporation , Including Carryover of NOLs
11 Tax-Free Reorganizations of C Corporations , Including Carryover of NOLs
12 Tax-Free Spin-Offs of C Corporations Under Section 355
VOLUME 2 PART III : PARTNERSHIPS 13 Organization of Partnerships :
Through the Lens of JV Agreements 14 Operation of Partnerships : Through the Lens of JV Agreements
15 Sales and Liquidations of Partnerships : Through the Lens of JV Agreements
PART IV : S CORPORATIONS 16 Organization of S Corporations 17 Operation of S Corporations 18 Dispositions of S Corporations or S Corporation Stock in Redemptions , Liquidations , Sales of Assets or of Stock , and Reorganizations
PART V : INTERNATIONAL PROVISIONS
19 Introduction to the International Provisions of the Internal Revenue Code , Including the General Impact of Tax Treaties
20 U . S . International Taxation of Inbound Activity : Investment in the U . S . by Foreign Persons
21 U . S . International Taxation of Outbound Activity : Investment in Foreign Countries by U . S . Persons
22 Federal Income Tax Considerations in Taxable Cross-Border M & A 23 Federal Income Tax Considerations in Tax-Free Cross-Border M & A
PART VI : A BRIEF INTRODUCTION TO STATE BUSINESS TAXATION 24 State Tax Considerations in Taxable and Tax-Free M & A
Table of Authorities Index
FOREIGN ACCOUNT TAX COMPLIANCE ACT ANSWER BOOK
Matthew D . Lee ( Fox Rothschild LLP )
Through an engaging question-and-answer format , this book guides tax lawyers and compliance professionals through the FATCA and its demands regarding annual FFI disclosure requirements . Organized by a preeminent tax controversy attorney with Department of Justice practice experience , this resource helps readers who counsel or work for FFIs understand the information these entities must share regarding ownership interests and accounts held by U . S . individuals .
Lawyers and stakeholders will find conversational discussions on key FATCA terms , concepts , and implementation trends . Readers can also access an in-depth library of important forms , compliance certification certificates , and periodic certification forms to reference as they carry out their FATCA compliance efforts .
Mastering FATCA compliance requires attorneys and FFI stakeholders to keep ahead of applicable regulatory developments . PLI ’ s Upkeep Service offers an automated , hassle-free approach to accomplish just this .
1 softbound volume or digital , 1,124 pages , $ 273 , Item # 318462 , ISBN 978-1-4024-4423-4 , Published as needed
CONTENTS
Frequently Used Terms
1 Background of the Foreign Account Tax Compliance
Act ( FATCA ) 2 Key FATCA Terms and Concepts 3 Classification of Non-U . S . Entities As Foreign
Financial Institutions 4 Withholding Obligations on Payments to Foreign
Financial Institutions 5 Identification of Payee 6 Obligations of Participating Foreign Financial Institutions 7 Foreign Financial Institution Agreement 8 Exempt Beneficial Owners 9 Withholding Obligations on Payments to Nonfinancial
Foreign Entities 10 Obligations of Withholding Agents to Withhold Tax and
File Returns 11 FATCA Responsible Officers and Compliance Programs 12 FATCA Implementation : 2014 and 2015 As
Transition Years 13 Intergovernmental Agreements 14 Frequently Asked Questions and Answers About FATCA
Registration , Withholding , and Reporting
Appendices [ 26 forms and draft certifications ] Index