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Federal Income Taxation of Corporations

6th Edition
Bret Wells | Charlene D. Luke | Martin J. McMahon, Jr. | Daniel L. Simmons
ISBN: 9798887866673
Subject: Tax-Corporate
Format: Print - Hardbound
Page Count: 1129
Copyright: 2024 | Status: In Stock
Other Formats Available

The 6th Edition explores the federal income taxation of corporations and their shareholders and can be used in a variety of courses covering corporate taxation at either the J.D. or LL.M. level. Numerous important revisions to the statutory structure over the past few decades—the changing magnitude of the capital gain preference, the preferential rate for dividends, the 2017 reduction to the corporate tax rate, a maximum individual rate now substantially higher than the maximum corporate rate, and repeal of the General Utilities rule providing nonrecognition of gain upon the distribution of property by a corporation—have changed dramatically the important issues. Most chapters and sections of chapters are introduced by a textual discussion or outline of the basic issues and structure of the statute governing treatment of the particular item or transaction covered in the chapter or section. This is followed by a principal case reading, generally a judicial decision but sometimes an IRS ruling or legislative history excerpt. A Detailed Analysis follows the principal case reading and is intended to facilitate the professor’s ability to tailor the class to the needs of a particular course through selecting portions of that analysis. Class Discussion Problems are incorporated directly into the text. In selecting and organizing the materials, we have attempted to maximize the usefulness of these materials for whatever approach the professor wishes to adopt—an intensive technical analysis, a problem-oriented method, a consideration of the policies that underlie the technical tax structure, or a survey of the principal elements of the federal income taxation of corporations.


Imprint: Foundation Press
Series: University Casebook Series
Publication Date: 07/22/2024

Bret Wells, University of Houston Law Center

Charlene D. Luke, University of Florida College of Law

Martin J. McMahon, Jr., University of Florida College of Law

Daniel L. Simmons, University of CA-Davis School of Law

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New for this edition:

  • In this 6th edition, the casebook has moved advanced content into “More to Consider” sections. This revision allows advanced topics to be separate and thus affords professors greater flexibility in designing their courses with this casebook. For example, JD programs that utilize this casebook could assign all material other than the “More to Consider” sections and thereby tailor their course to cover core materials without covering more advanced topics. However, because the advanced topics remain in the “More to Consider” section, JD programs and Tax LLM programs that do want to explore those advanced topics can do so by assigning the “More to Consider” sections as part of the assigned reading.
  • A discussion of the excise tax on stock buybacks adopted in the Inflation Reduction Act of 2022 was incorporated into Chapter 5.
  • A discussion of the detailed proposed regulatory guidance changes to the limitation on net operating losses computed under Section 382 is set forth in Chapter 12.
  • Other chapters were updated to include consideration of subsequent administrative and case law developments that occurred since publication of the 5th Edition.

Learn more about this series.