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Pearson's Federal Taxation 2022 Corporations, Partnerships, Estates & Trusts

Pearson's Federal Taxation 2022 Corporations, Partnerships, Estates & Trusts 35th Edition

By: Timothy J. Rupert Kenneth E. Anderson David S Hulse
/ ISBN-13: 9780137331345
Edition: 35th Edition
Language: English
				
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Tax Research

    • Overview of Tax Research
    • Steps in the Tax Research Process
    • Importance of the Facts to the Tax Consequences
    • Creating a Factual Situation Favorable to the Taxpayer
    • The Sources of Tax Law
    • The Legislative Process
    • The Internal Revenue Code
    • Treasury Regulations
    • Administrative Pronouncements
    • Judicial Decisions
    • Tax Treaties
    • Tax Periodicals
    • Tax Services
    • The Internet as a Research Tool
    • Keyword Searches
    • Search By Citation
    • Noncommercial Internet Services
    • Citators
    • Using the Citator
    • Professional Guidelines for Tax Services
    • Treasury Department Circular
    • Aicpa’s Statements on Tax Standards
    • Sample Work Papers and Client Letter
    • Problem Materials
    • Discussion Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy And Critical Thinking Problem
    • Case Study Problem
    • Tax Research Problems

Chapter 2 Corporate Formations and Capital Structure

    • Organization Forms Available
    • Sole Proprietorships
    • Partnerships
    • Corporations
    • Limited Liability Companies
    • Limited Liability Partnerships
    • Check-the-Box Regulations
    • Legal Requirements and Tax Considerations Related to Forming a Corporation
    • Legal Requirements
    • Tax Considerations
    • Section 351: Deferring Gain or Loss Upon Incorporation
    • The Property Requirement
    • The Control Requirement
    • The Stock Requirement
    • Effect of Sec. 351 on the Transferors
    • Tax Consequences to Transferee Corporation
    • Assumption of the Transferor’s Liabilities
    • Other Considerations in a Sec. 351 Exchange
    • Choice of Capital Structure
    • Characterization of Obligations as Debt or Equity
    • Debt Capital
    • Equity Capital
    • Capital Contributions by Shareholders
    • Capital Contributions by Nonshareholders
    • Worthlessness of Stock or Debt Obligations
    • Securities
    • Unsecured Debt Obligations
    • Tax Planning Considerations
    • Avoiding Sec. 351
    • Compliance and Procedural Considerations
    • Reporting Requirements Under Sec. 351
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 3 The Corporate Income Tax

    • Corporate Elections
    • Choosing a Calendar or Fiscal Year
    • Accounting Methods
    • Determining a Corporation’s Taxable Income and Tax Liability
    • Corporate Tax Rate
    • Sales and Exchanges of Property
    • Business Expenses
    • Special Deductions
    • Exceptions for Closely Held Corporations
    • Controlled Groups of Corporations
    • What Is a Controlled Group?
    • Application of the Controlled Group Test
    • Special Rules Applying to Controlled Groups
    • Consolidated Tax Returns
    • Tax Planning Considerations
    • Compensation Planning for Shareholder-Employees
    • Compliance and Procedural Considerations
    • Estimated Taxes
    • Requirements for Filing and Paying Taxes
    • When the Return Must Be Filed
    • Tax Return Schedules
    • Financial Statement Implications
    • Scope, Objectives, and Principles of ASC 740
    • Temporary Differences
    • Deferred Tax Assets and the Valuation Allowance
    • Accounting for Uncertain Tax Positions
    • Balance Sheet Classification
    • Tax Provision Process
    • Comprehensive Example – Year 1
    • Comprehensive Example – Year 2
    • Other Transactions
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 4 Corporate Nonliquidating Distributions

    • Nonliquidating Distributions in General
    • Earnings and Profits (E&P)
    • Current Earnings and Profits
    • Distinction Between Current and Accumulated E&P
    • Nonliquidating Property Distributions
    • Consequences of Nonliquidating Property Distributions to the Shareholders
    • Consequences of Property Distributions to the Distributing Corporation
    • Constructive Dividends
    • Stock Dividends and Stock Rights
    • Nontaxable Stock Dividends
    • Nontaxable Stock Rights
    • Effect of Nontaxable Stock Dividends on the Distributing Corporation
    • Taxable Stock Dividends and Stock Rights
    • Stock Redemptions
    • Tax Consequences of the Redemption to the Shareholder
    • Attribution Rules
    • Substantially Disproportionate Redemptions
    • Complete Termination of the Shareholder’s Interest
    • Redemptions Not Essentially Equivalent to a Dividend
    • Partial Liquidations
    • Redemptions to Pay Death Taxes
    • Effect of Redemptions on the Distributing Corporation
    • Preferred Stock Bailouts
    • Sec. 306 Stock Defined
    • Dispositions of Sec. 306 Stock
    • Redemptions of Sec. 306 Stock
    • Exceptions to Sec. 306 Treatment
    • Stock Redemptions by Related Corporations
    • Brother-sister Corporations
    • Parent-subsidiary Corporations
    • Tax Planning Considerations
    • Avoiding Unreasonable Compensation
    • Bootstrap Acquisitions
    • Timing of Distributions
    • Compliance and Procedural Considerations
    • Corporate Reporting of Nondividend Distributions
    • Agreement to Terminate Interest Under Sec. 302(b)(3)
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problem
    • Case Study Problems
    • Tax Research Problems

Chapter 5 Other Corporate Tax Levies

    • Use of C Corporation to Avoid Income Taxes
    • Personal Holding Company Tax
    • Personal Holding Company Defined
    • Stock Ownership Requirement
    • Passive Income Requirement
    • Calculating the PHC Tax
    • Avoiding the PHC Designation and Tax Liability by Making Dividend Distributions
    • PHC Tax Calculation
    • Accumulated Earnings Tax
    • Corporations Subject to the Penalty Tax
    • Proving a Tax-Avoidance Purpose
    • Evidence Concerning the Reasonableness of an Earnings Accumulation
    • Calculating the Accumulated Earnings Tax
    • Comprehensive Example
    • Tax Planning Considerations
    • Avoiding the Personal Holding Company Tax
    • Avoiding the Accumulated Earnings Tax
    • Compliance and Procedural Considerations
    • Personal Holding Company Tax
    • Accumulated Earnings Tax
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 6 Corporate Liquidating Distributions

    • Overview of Corporate Liquidations
    • The Shareholder
    • The Corporation
    • Definition of a Complete Liquidation
    • General Liquidation Rules
    • Effects of Liquidating on the Shareholders
    • Effects of Liquidating on the Liquidating Corporation
    • Liquidation of a Controlled Subsidiary
    • Overview
    • Requirements
    • Effects of Liquidating on the Shareholders
    • Effects of Liquidating on the Subsidiary Corporation
    • Special Reporting Issues
    • Pertaining to Shareholders
    • Pertaining to the Liquidating Corporation
    • Recognition of Gain or Loss When Property Is Distributed in Retirement of Debt
    • General Rule
    • Satisfaction of the Subsidiary’s Debt Obligations
    • Tax Planning Considerations
    • Timing the Liquidation Transaction
    • Recognition of Ordinary Losses When a Liquidation Occurs
    • Obtaining 80% Ownership to Achieve Sec. 332 Benefits
    • Avoiding Sec. 332 to Recognize Losses
    • Compliance and Procedural Considerations.
    • General Liquidation Procedures
    • Section 332 Liquidations
    • Plan of Liquidation
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 7 Corporate Acquisitions and Reorganizations

    • Taxable Acquisition Transactions
    • Asset Acquisitions
    • Stock Acquisitions
    • Comparison of Taxable and Nontaxable Acquisitions
    • Taxable and Nontaxable Asset Acquisitions
    • Comparison of Taxable and Nontaxable Stock Acquisitions
    • Types of Reorganizations and Their Tax Consequences
    • The Target or Transferor Corporation
    • The Acquiring or Transferee Corporation
    • Shareholders and Security Holders
    • Acquisitive Reorganizations
    • Type A Reorganization
    • Type C Reorganization
    • Type D Reorganization
    • Type B Reorganization
    • Type G Reorganization
    • Divisive Reorganizations
    • Divisive Type D Reorganization
    • Divisive Type G Reorganization
    • Other Reorganizations
    • Type E Reorganization
    • Type F Reorganization
    • Judicial Restrictions on the Use of Corporate Reorganizations
    • Continuity of Interest
    • Continuity of Business Enterprise
    • Business Purpose Requirement
    • Step Transaction Doctrine
    • Tax Attributes
    • Assumption of Tax Attributes
    • Limitation on Use of Tax Attributes
    • Tax Planning Considerations
    • Why Use a Reorganization Instead of a Taxable Transaction?
    • Avoiding the Reorganization Provisions
    • Compliance and Procedural Considerations
    • Section 338 Election
    • Plan of Reorganization
    • Party to a Reorganization
    • Ruling Requests
    • Financial Statement Implications
    • Taxable Asset Acquisition
    • Nontaxable Asset Acquisition
    • Stock Acquisition
    • Pricing The Acquisition
    • Net Operating Losses
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 8 Consolidated Tax Returns

    • Definition of an Affiliated Group
    • Requirements
    • Comparison With Controlled Group Definitions
    • Consolidated Tax Return Election
    • Consolidated Return Regulations
    • Termination of Consolidated Tax Return Filing
    • Consolidated Taxable Income
    • Accounting Periods and Methods
    • Income Included in the Consolidated Tax Return
    • Calculation of Consolidated Taxable Income and Tax
    • Intercompany Transactions
    • Basic Concepts
    • Matching and Acceleration Rules
    • Applications of Matching and Acceleration Rules
    • Relevance of Matching and Acceleration Rules
    • Items Computed on a Consolidated Basis
    • Charitable Contribution Deduction
    • Net Sec. 1231 Gain or Loss
    • Capital Gains and Losses
    • Dividends-received Deduction
    • Regular Tax Liability
    • Tax Credits
    • Estimated Tax Payments
    • Net Operating Losses (NOLs)
    • Current Year NOL
    • Carryovers of Consolidated NOLs
    • Special Loss Limitations
    • Stock Basis Adjustments
    • Tiering Up of Stock Basis Adjustments
    • Excess Loss Account
    • Tax Planning Considerations
    • Advantages of Filing a Consolidated Tax Return
    • Disadvantages of Filing a Consolidated Tax Return
    • Compliance and Procedural Considerations
    • The Basic Election and Return
    • Parent Corporation as Agent for the Consolidated Group
    • Separate Entity Treatment of Intercompany Transactions
    • Liability for Taxes Due
    • Financial Statement Implications
    • Intercompany Transactions
    • SRLY Losses
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problem
    • Case Study Problem
    • Tax Research Problems

Chapter 9 Partnership Formation and Operation

    • Definition of a Partnership
    • General and Limited Partnerships
    • Overview of Taxation of Partnership Income
    • Partnership Profits and Losses
    • The Partner’s Basis
    • Partnership Distributions
    • Tax Implications of Formation of a Partnership
    • Contribution Of Property
    • Contribution Of Services
    • Organizational And Syndication Expenditures
    • Partnership Elections
    • Partnership Tax Year
    • Other Partnership Elections
    • Partnership Reporting of Income
    • Partnership Taxable Income
    • Separately Stated Items
    • Partnership Ordinary Income
    • Special Deductions And Limitations
    • Partner Reporting of Income
    • Partner’s Distributive Share
    • Special Allocations
    • Basis for Partnership Interest
    • Beginning Basis
    • Effects of Liabilities
    • Effects of Operations
    • Special Loss Limitations
    • At-Risk Loss Limitation
    • Passive Activity Limitations
    • Limitation on Excess Business Losses
    • Transactions Between a Partner and the Partnership
    • Sales of Property
    • Guaranteed Payments
    • Family Partnerships
    • Capital Ownership
    • Donor-Donee Allocations of Income
    • Tax Planning Considerations
    • Timing of Loss Recognition
    • Guaranteed Payments
    • Compliance and Procedural Considerations
    • Reporting to the IRS and the Partners
    • IRS Audit Procedures
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problem
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 10 Special Partnership Issues

    • Nonliquidating Distributions
    • Recognition of Gain
    • Basis Effects of Distributions
    • Holding Period and Character of Distributed Property
    • Nonliquidating Distributions with Sec. 751
    • Section 751 Assets Defined
    • Exchange of Sec. 751 Assets and Other Property
    • Liquidating or Selling a Partnership Interest
    • Liquidating Distributions
    • Sale of a Partnership Interest
    • Other Partnership Termination Issues
    • Retirement or Death of a Partner
    • Exchange of a Partnership Interest
    • Income Recognition and Transfers of a Partnership Interest
    • Termination of a Partnership
    • Mergers and Consolidations
    • Division of a Partnership
    • Optional and Mandatory Basis Adjustments
    • Adjustments on Transfers
    • Adjustments on Distributions
    • Special Forms of Partnerships
    • Tax Shelters a nd Limited Partnerships
    • Publicly Traded Partnerships
    • Limited Liability Companies
    • Limited Liability Partnerships
    • Limited Liability Limited Partnership
    • Tax Planning Considerations
    • Liquidating Distribution or Sale to Partners
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problem
    • Case Study Problem
    • Tax Research Problems

Chapter 11 S Corporations

    • Should an S Election Be Made?
    • Advantages of S Corporation Treatment
    • Disadvantages of S Corporation Treatment
    • S Corporation Requirements
    • Shareholder-related Requirements
    • Corporation-related Requirements
    • Election of S Corporation Status
    • Making the Election
    • Termination of the Election
    • S Corporation Operations
    • Taxable Year
    • Accounting Method Elections
    • Ordinary Income or Loss and Separately Stated Items
    • Special S Corporation Taxes
    • Taxation of the Shareholder
    • Income Allocation Procedures
    • Income Pass-though to Shareholders
    • Loss and Deduction Pass-through to Shareholders
    • Family S Corporations
    • Basis Adjustments
    • Basis Adjustments to S Corporation Stock
    • Basis Adjustments to Shareholder Debt
    • S Corporation Distributions
    • Corporations Having No Earnings and Profits
    • Corporations Having Accumulated Earnings and Profits
    • Other Rules
    • Tax Preference Items and Other AMT Adjustments
    • Transactions Involving Shareholders and Other Related Parties
    • Fringe Benefits Paid to a Shareholder-Employee
    • Tax Planning Considerations
    • Election to Allocate Income Based on the S Corporation’s Accounting Methods
    • Increasing the Benefits from S Corporation Losses
    • Salary Levels
    • Passive Income Requirements
    • Compliance and Procedural Considerations
    • Making the Election
    • Filing the Corporate Tax Return
    • Estimated Tax Payments
    • Consistency Rules
    • Sample S Corporation Tax Return
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problem
    • Tax Research Problems

Chapter 12 The Gift Tax

    • The Unified Transfer Tax System
    • History and Purpose of Transfer Taxes
    • Unified Rate Schedule
    • Impact of Taxable Gifts on Death Tax Base
    • Unified Credit
    • Gift Tax Formula
    • Determination of Gifts
    • Exclusions and Deductions
    • Gift-Splitting Election
    • Cumulative Nature of Gift Tax
    • Unified Credit
    • Transfers Subject to the Gift Tax
    • Transfers for Inadequate Consideration
    • Statutory Exemptions from the Gift Tax
    • Cessation of Donor’s Dominion and Control
    • Valuation of Gifts
    • Gift Tax Consequences of Certain Transfers
    • Exclusions
    • Amount of the Exclusion
    • Present Interest Requirement
    • Gift Tax Deductions
    • Marital Deduction
    • Charitable Contribution Deduction
    • The Gift-Splitting Election
    • Computation of the Gift Tax Liability
    • Effect of Previous Taxable Gifts
    • Unified Credit Available
    • Comprehensive Illustration
    • Basis Considerations for a Lifetime Giving Plan
    • Property Received by Gift
    • Property Received at Death
    • Below-Market Loans: Gift and Income Tax Consequences
    • General Rules
    • De Minimis Rules
    • Tax Planning Considerations
    • Tax-Saving Features of Inter Vivos Gifts
    • Negative Aspects of Gifts
    • Compliance and Procedural Considerations
    • Filing Requirements
    • Due Date
    • Gift-splitting Election
    • Liability for Tax
    • Determination of Value
    • Statute of Limitations
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 13 The Estate Tax

    • Estate Tax Formula
    • Gross Estate
    • Deductions
    • Adjusted Taxable Gifts and Tax Base
    • Tentative Tax on Estate Tax Base
    • Reduction for Post-1976 Gift Taxes
    • Unified Credit
    • The Gross Estate: Valuation
    • Date-of-Death Valuation
    • Alternate Valuation Date
    • The Gross Estate: Inclusions
    • Comparison of Gross Estate with Probate Estate
    • Property in Which the Decedent Had an Interest
    • Dower or Curtesy Rights
    • Transferor Provisions
    • Annuities and Other Retirement Benefits
    • Jointly Owned Property
    • General Powers of Appointment
    • Life Insurance
    • Consideration Offset
    • Recipient Spouse’s Interest in QTIP Trust
    • Deductions
    • Debts and Funeral and Administration Expenses
    • Losses
    • Charitable Contribution Deduction
    • Marital Deduction
    • Computation of Tax Liability
    • Taxable Estate and Tax Base
    • Tentative Tax and Reduction for Post-1976 Gift Taxes
    • Unified Credit
    • Portability Between Spouses of Exemption Amount
    • Other Credits
    • Comprehensive Illustration
    • Liquidity Concerns
    • Deferral of Payment of Estate Taxes
    • Stock Redemptions to Pay Death Taxes
    • Special Use Valuation of Farm Real Property
    • Generation-Skipping Transfer Tax
    • Tax Planning Considerations
    • Use of Inter Vivos Gifts
    • Use Of Basic Exclusion Amount
    • What Size Marital Deduction Is Best?
    • Use of Disclaimers
    • Role of Life Insurance
    • Qualifying the Estate for Installment Payments
    • Where to Deduct Administration Expenses
    • Compliance and Procedural Considerations
    • Filing Requirements
    • Due Date
    • Valuation
    • Election of Alternate Valuation Date
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problems
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 14 Income Taxation of Trusts and Estates

    • Basic Concepts
    • Inception of Trusts
    • Inception of Estates
    • Reasons for Creating Trusts
    • Basic Principles of Fiduciary Taxation
    • Principles of Fiduciary Accounting
    • The Importance of Identifying Income and Principal
    • Principal and Income: The Uniform Act
    • Categorization of Depreciation
    • Formula for Taxable Income and Tax Liability
    • Gross Income
    • Deductions for Expenses
    • Distribution Deduction
    • Personal Exemption
    • Credits
    • Distributable Net Income
    • Significance of DNI
    • Definition of DNI
    • Manner of Computing DNI
    • Determining a Simple Trust’s Taxable Income
    • Allocation of Expenses to Tax-Exempt Income
    • Determination of DNI and the Distribution Deduction
    • Tax Treatment for Beneficiary
    • Shortcut Approach to Proving Correctness of Taxable Income
    • Effect of a Net Operating Loss
    • Effect of a Net Capital Loss
    • Comprehensive Illustration: Determining a Simple Trust’s Taxable Income
    • Determining Taxable Income for Complex Trusts and Estates
    • Determination of DNI and the Distribution Deduction
    • Tax Treatment for Beneficiary
    • Effect of a Net Operating Loss
    • Effect of a Net Capital Loss
    • Comprehensive Illustration: Determining a Complex Trust’s Taxable Income
    • Income in Respect of a Decedent
    • Definition and Common Examples
    • Significance of IRD
    • Grantor Trust Provisions
    • Purpose and Effect
    • Revocable Trusts
    • Post-1986 Reversionary Interest Trusts
    • Retention of Administrative Powers
    • Retention of Economic Benefits
    • Control of Others’ Enjoyment
    • Tax Planning Considerations
    • Ability to Shift Income
    • Timing of Distributions
    • Property Distributions
    • Choice of Year-End for Estates
    • Deduction of Administration Expenses
    • Compliance and Procedural Considerations
    • Filing Requirements
    • Due Date for Return and Tax
    • Documents to Be Furnished to IRS
    • Sample Simple and Complex Trust Returns
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Chapter 15 Administrative Procedures

    • Role of the Internal Revenue Service
    • Enforcement and Collection
    • Interpretation of the Statute
    • Audits of Tax Returns
    • Percentage of Returns Examined
    • Selection of Returns for Audit
    • Disclosure of Uncertain Tax Positions
    • Alternatives for a Taxpayer Whose Return Is Audited
    • 90-day Letter
    • Litigation
    • Requests for Rulings
    • Information to Be Included in Taxpayer’s Request
    • Will the IRS Rule?
    • When Rulings Are Desirable
    • Due Dates
    • Due Dates for Returns
    • Extensions
    • Due Dates for Payment of the Tax
    • Interest on Tax Not Timely Paid
    • Failure-to-File and Failure-to-Pay Penalties
    • Failure to File
    • Failure to Pay
    • Estimated Taxes
    • Payment Requirements
    • Penalty for Underpaying Estimated Taxes
    • Exceptions To The Penalty
    • Other More Severe Penalties
    • Negligence
    • Substantial Understatement
    • Transactions Without Economic Substance
    • Civil Fraud
    • Criminal Fraud
    • Statute of Limitations
    • General Three-Year Rule
    • Six-Year Rule for Substantial Omissions
    • When No Return is Filed
    • Other Exceptions to Three-Year Rule
    • Refund Claims
    • Liability for Tax
    • Joint Returns
    • Transferee Liability
    • Tax Practice Issues
    • Statutory Provisions Concerning Tax Return Preparers
    • Reportable Transaction Disclosures
    • Rules of Circular
    • Statements on Standards for Tax Services
    • Tax Accounting and Tax Law
    • Accountant-Client Privilege
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problem
    • Case Study Problem
    • Tax Research Problems

Chapter 16 U.S. Taxation Of Foreign-Related Transactions

    • The U.S. System of International Taxation
    • Participation Exemption System
    • Taxation of U.S. Citizens and Resident Aliens
    • Foreign Tax Credit
    • Foreign-Earned Income Exclusion
    • Taxation of Nonresident Aliens
    • Definition of Nonresident Alien
    • Investment Income
    • Trade or Business Income
    • Taxation of U.S. Businesses Operating Abroad
    • Domestic Subsidiary Corporations
    • Foreign Branches
    • Foreign Corporations
    • Potential Deferral of Tax on Foreign Earnings
    • Controlled Foreign Corporations
    • Deemed Paid Foreign Tax Credit
    • Passive and Mobile Income
    • Transfer Pricing
    • Inversions
    • Tax Planning Considerations
    • Deduction Versus Credit for Foreign Taxes
    • Election to Accrue Foreign Taxes
    • Special Earned Income Elections
    • Tax Treaties
    • Special Resident Alien Elections
    • Compliance and Procedural Considerations
    • Foreign Operations of U.S. Corporations
    • Reporting the Foreign Tax Credit
    • Reporting the Earned Income Exclusion
    • Filing Requirements for Aliens and Foreign Corporations
    • Financial Statement Implications
    • Foreign Tax Credit
    • Problem Materials
    • Discussion Questions
    • Issue Identification Questions
    • Problems
    • Comprehensive Problem
    • Tax Strategy and Critical Thinking Problems
    • Tax Form/Return Preparation Problems
    • Case Study Problems
    • Tax Research Problems

Quick Reference

    • 2021 Tax Rate Schedules and Other Key Numbers

Appendices

  • Appendix A Tax Research Working Paper File
  • Appendix B Tax Forms
  • Appendix C Macrs Tables
  • Appendix D Glossary
  • Appendix E Aicpa Statements On Standards For Tax Services Nos. 1–7
  • Appendix F Comparison Of Tax Attributes For C Corporations, Partnerships, And S Corporations
  • Appendix G Actuarial Tables
  • Appendix H Index Of Code Sections
  • Appendix I Index Of Treasury Regulations
  • Appendix J Index Of Government Promulgations
  • Appendix K Index Of Court Cases
  • Appendix L Subject Index

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