Tax: Advanced Corporate Tax
LAW 698 Section 61
Deborah A. Geier
Required Texts
(1) Taxation of Business Enterprises by Peroni & Bank (Thomson West 4th ed. 2012) (ISBN 978-0-314-19487-9)
(2) Access to the Internal Revenue Code & Regulations in class. I shall be using Selected Federal Taxation—Statutes and Regulations (West 2019 ed.) (ISBN ISBN 978-1-64020-817-9). If you purchased a hard copy of the 2018 edition last year for your tax classes, however, you can continue using that version this year, as the TCJA did not meaningfully amend the corporate tax provisions that we’ll be examining in this course, with the exception of the corporate tax rate in § 11 (now 21% instead of a top rate of 35%). Alternatively, you may avoid the cost of a hard copy by accessing the Code sections and related Treasury Regulations that we shall study online. You can simply type the code section (e.g., IRC 61) or treasury regulation (e.g., TR 1.61-2) into your browser’s search box, and the first item to come up will be the Legal Information Institute’s version of the code section or regulation. The LII is hosted by Cornell law school, and it is the source that I used for the hyperlinks in my Tax I e-textbook.
One word of warning, however. You will not be able to access either the internet or your hard drive during the final exam (unlike your Tax I exam), so those of you choosing online access only may wish to print out some of the Code sections and Treasury Regulations that you wish to have with you during the final exam.
First Class Assignment: Taxable Corporate Acquisitions
Review from Tax II §§ 351(a); 331(a); 332(a); 336(a); 337(a); 334(a), (b). Read p. 352-68 of the text and §§ 338(a), (d)(3), (h)(3), and (h)(10).