Introduction:

The federal income taxation of corporations and their shareholders in the United States is introduced in this training program. It on the requirements of Subchapter C of the Internal Revenue Code that apply to the creation, operation, distribution, and dissolution of corporations, as well as the associated Treasury Regulations and judicial decisions.

Program Objectives:

At the end of this program, the participants will be able to:

Have a relatively brief summary of a business entity tax topic.
Specialize in partnership and corporate taxation or are working on an LL.M.
Expand their practices into business entity taxation.
Practice in the area of business entity taxation.

Targeted Audience

Members of the financial accounting team.
Finance managers and employees in cost and management accounting.
Budget supervisors.
Experienced lawyers.
Financial commitment and participants in the project.
Members of the acquisition team and investment analysts.

Program Outline:

Unit 1:

Overview of Business Taxation:

Origins of Taxation.
Sources of Tax Law.
Judicial Doctrines.
Hierarchy of Tax Law Sources.
Fundamental Features.
Strategic Form Choice.

Unit 2:

Corporate Income Taxation:

Income Tax Formulas.
Dividends Received Deduction.
Organizational Expenditures Deduction: Concepts.
Regular Corporate Income Tax Liability.
Corporate Alternative Minimum Tax.
Penalty Taxes on Corporate Accumulations.

Unit 3:

Corporate Formation I:

Acquisition and Disposition Recognition.
Character Recapture.
Recapping Recapture.
Sunchaser Shakery Introduction to Non-Recognition Provisions.
Non-Recognition Provisions: Concepts Applications.
Basis Determination & Holding Period: Concepts Applications.
Built-In Loss Property: Concepts Applications.
Treatment of “Boot”: Concepts Applications.

Unit 4:

Corporate Formation II:

Assumption of Liabilities: Concepts Applications.
Property and Services: Concepts Applications.
Capital Contributions: Concepts Applications.
Debt versus Equity: Concepts Applications.
Investor Losses: Concepts Applications.
Small Business Stock: Concepts Applications.

Unit 5:

Taxation Considerations:

Related Corporations Differences.
Compliance Procedures.

Taxation of Corporations Business Entities