The Eighth Edition of this leading casebook continues the tradition of teaching the "fundamentals" of a highly complex subject through the use of clear and concise explanatory text, skillfully drafted problems, and a selective mix of original source materials to accompany the Code and regulations. It incorporates all new developments and refines or eliminates some materials from earlier editions that have become less relevant to contemporary practice. Important highlights include: Full coverage, with examples and revised problems, of all significant amendments to Subchapter K made by the American Jobs Creation Act of 2004, with particular emphasis on new statutory rules to prevent transfers and duplication of partnership losses. A chapter on S corporations, reflecting the more permissive eligibility requirements and other new statutory rules. Discussion of the impact of recent tax legislation on choice of business entity, including analysis of I.R.S. data on current trends. A recent published ruling on partnership mergers and terminations and summaries of other new partnership tax cases and rulings. Explanations of the policies underlying the statutory rules as well as the technical details.

The ninth edition teaches the fundamentals of a highly complex subject through clear and lively explanatory text, skillfully drafted problems, and a selective mix of original source materials. Highlights include: Coverage of all significant developments since the last edition, including proposed regulations interpreting the � 706 varying interest rule and defining "interest in a limited partnership" for purposes of the � 469 passive loss limitations A fresh perspective on choice of entity, including employment tax considerations New author's text discussing series LLCs and partnership debt-for-equity exchanges Revised text on special allocations under � 704(b) An update on the partnership "carried interest" controversy Pruning of dated materials and more tightly edited cases, notes and problems

The Eleventh 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 and well edited 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 tax legislation known as the Tax Cuts and Jobs Act. Highlights of new material covered in the Eleventh 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 a new problem set. 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. The three-year long-term holding period required by § 1061 for capital gains allocable to service partners with carried interests. Final, temporary and proposed regulations on partnership liabilities and the special treatment of bottom dollar payment obligations. New limitations in § 461(l) on excess business losses. Technical changes to Subchapter K, including the expanded definition of "substantial built-in loss" under § 743(b) and repeal of the technical termination rule in § 708. S corporation developments, including the requirement to pay reasonable compensation to shareholder-employees for purposes of the § 199A qualified business income deduction.

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.