The Tenth Edition of this widely used casebook continues its long tradition of teaching the “fundamentals” of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, and a rich mix of original source materials to accompany the Code and regulations. This extensive revision discusses all significant developments since the last edition, including relevant provisions of the 2017 legislation known as the Tax Cuts and Jobs Act. Highlights of new material covered in the Tenth Edition are:
- The impact on choice of entity of the 21% corporate income tax rate, lower individual income tax rates, the 20% deduction for qualified business income, and other tax and business planning considerations.
- A revised discussion of corporate capital structure to reflect the changed stakes resulting from the reduction of the corporate income tax rate and the new § 163(j) limitation on the deduction of business interest.
- Developments affecting corporate divisions under § 355, including the IRS’s changed ruling policy and proposed regulations dealing with divisions involving significant cash and other nonbusiness assets.
- Other technical changes to Subchapter C, including a revised definition of contributions to capital, reductions of the dividends received deduction, modifications to the net operating loss deduction, safe harbor valuation methods to measure continuity of proprietary interest, and the reduced role of the limitations on multiple tax benefits for affiliated corporations.
- S corporation developments, with an overview and a new problem on the § 199A deduction for 20% of qualified business income from pass-through entities and the requirement to pay reasonable compensation to shareholder-employees of S corporations.