For each type of entity, qualification, formation, conversion, operation, and termination issues are addressed along with use of the entity in specific contexts including corporate reorganizations, partnership transactions, and like-kind exchanges. Scott, United States Tax Court (1980-1982); co-author, Collier on Bankruptcy Taxation (Matthew Bender 2001), part of the nationally recognized Collier on Bankruptcy 15th Edition; National Director (retired), Deloitte Tax, LLP, Phoenix, Arizona; member, American Bar Association Section of Taxation (Council, 2004-06; past Chair, Real Estate Committee, 1996-98), State Bar of Arizona. Application of specific provisions such as the at-risk rules and the cancellation of indebtedness provisions are discussed. Use of disregarded entities in cross-border transactions and their impact on the direct and indirect foreign tax credit also are described. A., University of California at Irvine (1976; summa cum laude); J.
Tax Consequences of the Election (1) From Association Taxable as a Corporation to Disregarded Entity (2) From Disregarded Entity to Association Taxable as a Corporation 2.
Disregarded Entities and Specific Code Provisions 1.
Transfer of Disregarded Entity Assets Subject to Debt b.
Tax Management Portfolio, Disregarded Entities, No. 704-2nd, discusses entities that are recognized as having a legal status separate from their owners for certain purposes but are totally ignored for federal income tax purposes.
The three types of disregarded entities are entities disregarded under the elective classification regime, qualified S corporation subsidiaries, and qualified real estate investment trust subsidiaries.
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704-2nd, discusses entities that are recognized as having a legal status separate from their owners for certain purposes but are totally ignored for federal income tax purposes.
2009); co-author, Federal Corporate Taxation (Foundation Press: 7th ed.
2012); co-author, Fundamentals of US Taxation (Kluwer Law International: 1999); member, District of Columbia Bar; member, American Law Institute; member, American Bar Association, Tax Section.