Federal and State Taxation of Limited Liability Companies 2009

Federal and State Taxation of Limited Liability Companies 2009

Author: David J. Cartano

Publisher: CCH

Published: 2008

Total Pages: 984

ISBN-13: 9780808019138

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Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples. This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable.


Author:

Publisher: Cengage Learning

Published:

Total Pages: 1704

ISBN-13: 0357900529

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Remedying Flaws in the Hot Asset Sale Approach

Remedying Flaws in the Hot Asset Sale Approach

Author: Karen C. Burke

Publisher:

Published: 2015

Total Pages: 0

ISBN-13:

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Notice 2006-14 requests comments concerning revision of the longstanding regulations under section 751(b) to reflect the modern concepts of revaluations and reverse section 704(c) allocations. The ABA and NYSBA have responded recently by recommending a deemed-sale approach, modeled on section 704(c)(1)(B), that would trigger ordinary income under section 751(b) whenever a partner's aggregate share of hot asset gain is reduced following a current or liquidating distribution. In this special report, Prof. Burke recommends that the deemed-sale approach be extended to current distributions that leave the distributee with booked-up hot asset gain in excess of the distributee's retained interest in partnership capital. Together, sections 704(c)(1)(B) and 751(b)provide a coherent solution to the problem of shifting hot and cold asset gain following a partnership distribution. By eliminating the need for spectral section 704(c) allocations to reflect value-basis disparities inherent in distributed property, such an approach would allow reverse section 704(c) allocations to function properly. While the drafters of the 1954 code considered a section 704(c)-type approach excessively complex, the section 704(b) regulations now generally require revaluations and reverse section 704(c) allocations. The author wishes to thank Prof. William D. Andrews for helpful comments and suggestions.


Mergers, Acquisitions, and Buyouts

Mergers, Acquisitions, and Buyouts

Author: MARTIN D. GINSBURG

Publisher: Wolters Kluwer Law & Business

Published: 2022-01-23

Total Pages: 4950

ISBN-13: 1543837107

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Mergers, Acquisitions, and Buyouts, December 2021 By Martin D. Ginsburg, Jack S. Levin, Donald E. Rocap When structuring mergers and acquisitions, there's only one way to be sure that you've thought of all the tax and legal consequences: rely on Martin D. Ginsburg, Jack S. Levin and Donald E. Rocap as you plan, develop, and execute your mergers and acquisitions strategy. In this gold-standard resource for mergers and acquisitions analysis and guidance--available as a five-volume print set, a bundle with the print and CD-ROM editions, or online--these expert practitioners offer you: * Solutions to real-life business merger problems as they arise in negotiations * Step-by-step analysis of typical and non-typical company buyout and company merger transactional permutations * Checklists, flow charts, and other at-a-glance mergers practice materials Whether you represent the buyer, the seller, or another interested party, you can go straight to a model M&A agreement that gives you: * A complete document structured to embody your client's M&A interests * Clauses addressing a wide variety of specific mergers and acquisitions situations * Specific language for even the smallest mergers and acquisitions variations you're likely to encounter * Includes CD-ROM containing Mergers, Acquisitions, and Buyouts: Sample Acquisition Agreements When it comes to companies buying other companies--particularly public company acquisitions--seemingly every transaction raises something unique, Mergers, Acquisitions, and Buyouts is recently updated with: * New step-by-step methods for structuring transactions, with tax, SEC, corporate, HSR, accounting and other mergers considerations * New table summarizing and contrasting terms of pro-buyer, pro-seller, and neutral stock & asset purchase agreements * Practical guidance based on the latest mergers and acquisition news and the most recent corporate acquisition developments * New mergers legislation, M&A regulations, rulings, and M&A litigation outcomes impacting M&A transactions as reflected in recent mergers and acquisitions Frequently asked questions covered in Mergers, Acquisitions, and Buyouts: * What are the tax considerations in our M&A transaction? * Are there recent deals or developments affecting our M&A transaction? * How do we handle unwanted assets? * How do we handle reorganizations that are "solely for voting stock"? * What are the tax aspects of LBO structuring and financing? * What should we be taking into consideration regarding management compensation? * How do you execute a mergers and acquisitions strategy using Partnership, LLC, or REIT?


Internal Revenue Cumulative Bulletin 2006-1, January-June

Internal Revenue Cumulative Bulletin 2006-1, January-June

Author: Internal Revenue Service (U S )

Publisher: Government Printing Office

Published: 2007-06

Total Pages: 1230

ISBN-13:

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NOTE: NO FURTHER DISCOUNT FOR THIS PRINT PRODUCT--OVERSTOCK SALE -- Significantly reduced list price while supplies last Includes Revenue Rulings 2006-1 to 2006-34, Revenue Procedures 2006-1 to 2006-28, and Treasury Decisions 9231 to 9264. Consolidates all items of a permanent nature published in the weekly "Internal Revenue Bulletin" from issue 2006-1 through 2006-26 for the period of January 1 through June 30, 2006. Related products: Other products produced by the U.S. Treasury, Internal Revenue Service can be found here: https://bookstore.gpo.gov/agency/228