Federal Income Taxation of Corporations - 6th Edition - Bret Wells

Federal Income Taxation of Corporations 6th Edition ISBN 9798887866673

The 6th Edition offers a comprehensive exploration of the federal income taxation of corporations and their shareholders. It is designed for use in a variety of courses on corporate taxation at both the J.D. and LL.M. levels.

This edition reflects significant statutory developments over the past several decades, including:

• Shifts in the capital gains preference,
• Preferential tax rates for dividends,
• The 2017 reduction in the corporate tax rate,
• A current maximum individual tax rate that now exceeds the corporate rate, and
• The repeal of the General Utilities rule, which previously allowed nonrecognition of gain upon corporate property distributions.

These changes have substantially reshaped the key issues in corporate tax law.

Each chapter or section typically begins with a textual overview that outlines the core statutory structure and key issues related to the transaction or item under discussion. This is followed by a principal case—usually a judicial decision, but occasionally an IRS ruling or excerpt from legislative history—selected to illustrate central themes.

A Detailed Analysis follows the principal case and is designed to support faculty in tailoring class content to their course goals. Class Discussion Problems are integrated directly into the text to encourage active engagement.

In selecting and organizing the materials, our objective has been to provide maximum flexibility for instructors—whether their approach emphasizes technical depth, policy considerations, problem-solving, or a broad survey of corporate tax principles.

Updates in the New Edition:

The 6th Edition introduces several important structural and substantive updates:

• “More to Consider” Sections: Advanced content has been moved into clearly marked “More to Consider” sections. This redesign provides instructors with greater flexibility in course design. For example, J.D. programs may focus solely on the core materials by excluding the “More to Consider” sections, while both J.D. and Tax LL.M. programs may assign these sections to explore more advanced topics in greater depth.
• Stock Buyback Excise Tax: Chapter 5 now includes a discussion of the 1% excise tax on corporate stock repurchases introduced in the Inflation Reduction Act of 2022, offering timely analysis of this recent legislative development.
• Section 382 Regulatory Guidance: Chapter 12 addresses the detailed proposed regulatory changes concerning the limitation on net operating losses under Section 382, incorporating the most current interpretive framework for this complex area.
• Ongoing Updates Throughout: Numerous chapters have been revised to reflect important administrative and judicial developments that have occurred since the publication of the 5th Edition.

These updates ensure that the casebook remains current, adaptable, and relevant for a wide range of law school courses in corporate taxation.

Wells, Luke, McMahon and Simmons Federal Income Taxation of Corporations Sixth Edition ISBN 9798887866673 & 979-8887866673