Offered as an alternative to the authors' widely used separate texts on corporate and partnership tax, the Seventh Edition of this comprehensive casebook continues its tradition of providing an integrated approach to teaching the "fundamentals" of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, selective discussion of tax policy issues, and a rich mix of original source materials to accompany the Code and regulations. This extensive revision discusses all major developments since the last edition, emphasizing significant provisions of the 2017 tax legislation known as the Tax Cuts and Jobs Act. Highlights of new material covered in the Seventh Edition are: The deduction under § 199A for 20% of qualified business income from a pass-through entity. The discussion incorporates the final regulations and includes new problems. The impact on choice of entity of the 21% corporate income tax rate, lower individual rates, the 20% deduction for qualified business income, and other tax and business planning considerations. The new three-year long-term holding period required for capital gains allocable to service partners with carried interests in certain investment partnerships. 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. New limitations on the deduction of excess business losses. Other technical changes to Subchapters K and C and regulatory developments affecting partnership liabilities and corporate divisions. S corporation developments, including the requirement to pay reasonable compensation to shareholder-employees for purposes of the § 199A qualified business income deduction.

The fifth edition of this comprehensive casebook teaches the fundamentals of business enterprise taxation with clear and concise explanatory text, skillfully drafted problems, and a rich mix of original source materials. Highlights cover all significant developments since the last edition, including: The impact of changing tax rates Final and proposed regulations under Subchapters C and K Full text of a 2008 published ruling on application of the step transaction doctrine to multi-step acquisitions Codification of the economic substance doctrine, the accompanying strict liability penalty, and their implications for transactional planning A fresh perspective on choice of entity and an update on the "carried interest" controversy

Fundamentals of Business Enterprise Taxation is available as an alternative to the authors' widely used separate texts on corporate and partnership tax. It covers all the basics and offers more condensed coverage of a few advanced topics for a consolidated J.D.-level course on taxation of business enterprises. The Third Edition is faithful to the authors' problem-oriented "fundamentals" approach and incorporates all relevant changes made by the American Jobs Creation Act of 2004 and the Jobs and Growth Tax Relief Reconciliation Act of 2003. Important new highlights include: Fully integrated discussion of the impact of the reduced tax rates on qualified dividends and capital gains on transactions between business entities and their owners Policy-based explanations of new statutory rules preventing transfers and duplication of losses in the partnership and C corporation settings. Discussion of the impact of recent tax legislation on choice of business entity, including analysis of I.R.S. statistical data on contemporary trends. Updated chapters on corporate reorganizations and S corporations, reflecting the Service's evolving liberal approach to continuity of interest, multi-step acquisitions and corporate divisions, and the more permissive S corporation eligibility requirements. New published rulings on partnership mergers and terminations and corporate divisions, and discussion of all new relevant proposed and final regulations.

The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.