Details

This course covers the basic principles of partnership taxation under Subchapter K and corporate taxation under Subchapters C and S of the Internal Revenue Code. As a follow-up to the basic course in federal income taxation, the course will first consider the tax aspects of business operations conducted through a partnership or corporation, including the treatment of gains and losses, and the tax implications for both the investor (the partner or shareholder) and the entity (the partnership or corporation) on the distribution of cash or property from the entity to the investor. Attention will then be paid to tax issues arising on the creation of the business entity, typically the contribution of cash and property by the investors to the entity, and the tax issues confronted on the dissolution and liquidation of the business entity, typically the distribution of cash or property to the investors from the entity. Finally, the course will consider the specific provisions in Subchapter C concerning the tax implications of corporate reorganizations and restructurings, including corporate mergers, divisions, and acquisitions. The course adopts a comparative perspective in which the tax provisions applicable to partnerships and corporations as the course progresses will be considered together rather than focusing in one half of the course on partnership taxation and in the other half of the course on corporate taxation. Evaluation: Final Examination Teaching Method: Lecture/Problem Method Prerequisite: Basic Federal Income Tax