Fundamentals of Business Enterprise Taxation

Stephen Schwarz, UC College of the Law, San Francisco

Daniel J. Lathrope, University of San Francisco School of Law

Brant J. Hellwig, New York University School of Law

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Table of Contents

2023 Student Update

2023 Teacher's Manual Update

Teacher's Manual

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.

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