Monday, August 30, 2010

BP, Oil Spills, and Giving Up Tax Breaks

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The news of a few weeks ago (see, e.g., this report ) that BP intended to claim deductions and credits arising from expenditures has caused ...
Friday, August 27, 2010

A Tax on Blog Writing or on Blog Business?

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The blogosphere is in a tizzy over the news from Philadelphia that the city is imposing its $300 business privilege license fee on bloggers...
Wednesday, August 25, 2010

Pennsylvania State Gasoline Tax Increase: The Last Hurrah?

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Several years ago, in Are State Gasoline Taxes the Best Source of Highway Revenue? , I pointed out that Pennsylvania faces a a $1.7 billion ...
Monday, August 23, 2010

The Internet, Virtual Meetings, and Taxation

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A recent decision, Foundation of Human Understanding v. U.S. , No. 2009-5129 (Fed. Cir. Aug. 16, 2010), demonstrates the continuing difficul...
Friday, August 20, 2010

Tax Politics and Economic Uncertainty

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According to Martin Regalia, chief economist of the U.S. Chamber of Commerce, “Uncertainty is the probably the biggest factor retarding econ...
Wednesday, August 18, 2010

DRPA Reform Bandwagon: Finally Gathering Momentum

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Some time ago, I criticized the decision of the Delaware River Port Authority to use toll revenues for contributions to the construction of ...
Monday, August 16, 2010

Structuring Introduction to Taxation of Business Entities: Part XX

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The syllabus for Introduction to Taxation of Business Entities includes one last topic, namely, Introduction to Reorganizations. Only twice ...
Friday, August 13, 2010

Structuring Introduction to Taxation of Business Entities: Part XIX

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Three partnership liquidation patterns are considered. Only one gets extensive attention. The first pattern is a so-called true liquidation,...
Wednesday, August 11, 2010

Structuring Introduction to Taxation of Business Entities: Part XVIII

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As the course winds down, the transactions that mark the end of an entity’s existence take center stage. The word liquidation presents almos...
Monday, August 09, 2010

Structuring Introduction to Taxation of Business Entities: Part XVII

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The partnership redemptions topic consists of two major subtopics. One deals with partial reductions in a partnership interest. The other de...
Friday, August 06, 2010

Structuring Introduction to Taxation of Business Entities: Part XVI

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Having explored sales of interests, the class turns to the tax consequences of corporate redemptions. Even though corporate redemptions rese...
Wednesday, August 04, 2010

Structuring Introduction to Taxation of Business Entities: Part XV

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There are three topics dealing with sales of interests in the entity. Only one receives any significant amount of class time. In the case of...
Monday, August 02, 2010

Structuring Introduction to Taxation of Business Entities: Part XIV

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After dealing with operating distributions of cash and property, the course advances to the topic of corporations distributing stock. There ...
Friday, July 30, 2010

Structuring Introduction to Taxation of Business Entities: Part XIII

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The discussion of partnership operating distributions begins with clarification of terminology. Students learn that one set of rules applies...
Wednesday, July 28, 2010

Structuring Introduction to Taxation of Business Entities: Part XII

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In comparison to the tax treatment of C corporation operating distributions, the principles applicable to S corporation operating distributi...
Monday, July 26, 2010

Structuring Introduction to Taxation of Business Entities: Part XI

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From a pedagogical perspective it makes the most sense to deal with operating distributions before covering sales of entity interests, redem...
Friday, July 23, 2010

Structuring Introduction to Taxation of Business Entities: Part X

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Having worked through section 704(b) special allocations, the class turns to section 704(c). The good news is that section 704(c) is much ea...
Wednesday, July 21, 2010

Structuring Introduction to Taxation of Business Entities: Part IX

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The partnership allocation topic is, without a doubt, the most difficult portion of the Introduction to Taxation of Business Entities course...
Monday, July 19, 2010

Structuring Introduction to Taxation of Business Entities: Part VIII

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The notion of allocations in the C corporation context isn’t so much a matter of allocation as it is a question of who is taxed on income th...
Friday, July 16, 2010

Structuring Introduction to Taxation of Business Entities: Part VII

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It might appear that studying loss limitations before looking at allocations is backwards, but understanding how loss limitations work puts ...
Wednesday, July 14, 2010

Structuring Introduction to Taxation of Business Entities: Part VI

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After completing the formation topics, the course next addresses how corporations and partnerships are taxed on their operations. There are ...
Monday, July 12, 2010

Structuring Introduction to Taxation of Business Entities: Part V

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The partnership formation topic is divided into three subtopics. The first subtopic involves transfers of cash and propety to a partnership ...
Friday, July 09, 2010

Structuring Introduction to Taxation of Business Entities: Part IV

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After working through the entity identification material, the course addresses the federal income tax consequences of forming corporations a...
Wednesday, July 07, 2010

Structuring Introduction to Taxation of Business Entities: Part III

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After finishing with the introduction, the course turns to identification of the entity. Although sometimes the context of a question or pro...
Monday, July 05, 2010

Structuring Introduction to Taxation of Business Entities: Part II

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One of the first decisions I needed to make with respect to the course was a choice between what I call categorical sequencing and what I ca...
Friday, July 02, 2010

Structuring Introduction to Taxation of Business Entities: Part I

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Today I begin a series describing how and why I have structured the Introduction to Taxation of Business Entities course that I teach in the...