Fundamentals of Business Enterprise Taxation - 8th Edition - Stephen Schwarz

Fundamentals of Business Enterprise Taxation 8th Edition Stephen Schwarz

ISBN: 9798317701734

Offering an integrated alternative to the authors’ widely used separate casebooks on corporate and partnership taxation, the Eighth Edition of this comprehensive text continues its tradition of making a complex subject accessible through clear explanations, carefully designed problems, selective discussions of tax policy, and a rich collection of primary source materials supplementing the Internal Revenue Code and regulations.

This extensive revision incorporates all major developments since the previous edition, including relevant provisions of the tax legislation known as the One Big Beautiful Bill Act. Key updates include:

• Choice of Entity: Updated coverage of the tax and other planning considerations involved in selecting an appropriate entity for a new business.
• Partner-Level Taxation: A new chapter examining tax issues affecting individual partners, including eligibility for the § 199A qualified business income deduction in the partnership context and the application of self-employment and net investment income taxes to partnership income.
• Partnership Allocations: Expanded coverage of targeted allocations, including a new practical problem.
• Partnership Liabilities and Carried Interests: Coverage of final regulations addressing bottom-dollar payment obligations, anti-abuse limitations on the allocation of recourse liabilities, and § 1061 rules governing the recharacterization of gains earned by partners holding carried interests.
• Judicial Developments: Analysis of the D.C. Circuit's decision in Rawat v. Commissioner and its implications for applying § 751(a) to sales and exchanges of partnership interests.
• Corporate Capital Structure: Revised discussion, including expanded coverage of the § 1202 exclusion for gains from the sale of qualified small business stock.
• Stock Buybacks: New coverage of the § 4501 excise tax on stock repurchases.
• Corporate Reorganizations: A new problem addressing reorganization structures involving an entity wholly owned by the acquiring corporation.
• Corporate Divisions: Updated discussion of the IRS's ruling policy, reorganized coverage of the § 355 active trade or business requirement, and new material on the relevance of the § 336(e) election.
• Economic Substance Doctrine: Coverage of recent developments concerning the scope of the codified doctrine.
• Tax Policy: Updated policy discussions throughout the casebook.
• Streamlined Materials: Removal of outdated content and more focused editing of cases, notes, and problems.

Combining corporate and partnership taxation in a single, cohesive text, the Eighth Edition provides students with a thorough and practical foundation in business taxation while incorporating the latest legislative, regulatory, and judicial developments.

Fundamentals of Business Enterprise Taxation 2027 8th Edition Stephen Schwarz
ISBN: 9798317701734, 979-8317701734, 979-8-3177-0173-4, 979-8-31770-173-4

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

Heather M. Field, UC College of the Law, San Francisco