Earnings and profits [electronic resource] / David Friedel, Esq., William Galanis, Esq., and Julie Allen, CPA, PricewaterhouseCoopers LLP, Washington, D.C.
" ... discusses the principles and rules associated with earnings and profits (E & P). Since the tax treatment of a distribution of property with respect to a corporation's stock is directly related to a corporation's E & P, the correct determination of a corporation's E...
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| Online Access: |
Law Students, Faculty, and Staff (via Bloomberg Law) |
|---|---|
| Main Authors: | , , |
| Other title: | Bloomberg Law online Bloomberg Law online. |
| Format: | Electronic Website |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management,
[2002]-
|
| Series: | Tax management portfolios ;
762-4th. |
| Subjects: |
Table of Contents:
- Detailed Analysis. I. Introduction
- Part I: Rules Applicable to Separate Returns
- II. General Principles
- III. Distributions of Property
- IV. Distributions of Stock or Securities ([section] 312(d))
- V. Effect of Gain or Loss on E and P ([section] 312(f)(1))
- VI. Effect of Receipt of Tax-Free Distributions on E and P
- VII. Allocation in Certain Reorganizations
- VIII. Distribution of Proceeds of Loan Insured by the U.S.
- IX. Prior Law
- Sale of Stock of Foreign Investment Company
- X. Depreciation and Amortization
- XI. Discharge of Indebtedness Income
- XII. Interest Paid on Certain Registration-Required Obligations Not in Registered Form
- XIII. Adjustments to E and P to More Accurately Reflect Economic Gain and Loss
- XIV. Section 304 Redemptions Using Related Corporations
- XV. Special Rules for RICs and REITs
- XVI. Corporate Distributions with Respect to Stock
- XVII. E and P Carryover in Corporate Acquisitions: Section 381 Transactions
- Part II: Consolidated Return Aspects of E and P
- XVIII. Earnings and Profits of Consolidated Group Members
- In General
- XIX. History of Consolidated Return E and P Rules
- XX. Application of 1995 Regulations
- XXI. Treatment of Particular Transactions
- XXII. Predecessors and Successors
- XXIII. Anti-Avoidance
- Working papers.