This edition has been completely revised to reflect the 2017 Act and developments through October 2023. The text focuses on the corporation as a taxable entity and tracks the corporate life cycle from incorporation through complete liquidation. It includes discussion on nonliquidating distributions, redemptions, and stock dividends. It also addresses advanced problems in corporate taxation, such as taxable acquisitions, tax-free reorganizations and corporate divisions, and carryover of corporate tax attributes.


Imprint: West Academic Publishing
Series: Nutshells
Publication Date: 02/05/2024

Karen C. Burke, University of Florida College of Law

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The Ninth Edition is updated to reflect the Inflation Reduction Act of 2022 and other recent legislative and regulatory changes, including:

  • the newly-enacted alternative minimum tax of 15% on the adjusted financial statement income of certain large C corporations
  • imposition of a 1% excise tax on the value of stock “repurchased” by a publicly-traded corporation
  • relief permitting a nonresident alien to be a potential current beneficiary of an electing small business trust (ESBT) without terminating S status
  • withdrawal of proposed regulations addressing allocation and recovery of basis in transactions involving corporate stock, including § 351 transfers
  • the Service’s no-rule policy on certain § 355 transactions and ongoing study concerning the definition of an active trade or business
  • final regulations under § 385 classifying instruments as debt or equity for federal tax purposes
  • enactment of elective entity-level passthrough taxes intended to avoid the individual limit on deductibility of state and local taxes

Learn more about this series.