Taxation of Corporations Business Entities

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.