Product Review

The ninth edition of this widely used casebook continues its long tradition of teaching the “fundamentals” of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the ninth edition include:

• Coverage of all significant developments since the last edition, including the impact on corporate-shareholder transactions of the now permanent higher marginal individual tax rates and the 3.8% tax on net investment income tax; final regulations on § 336(e) elections and Type F reorganizations; published rulings on internal corporate restructuring transactions; new legislation blocking tax-free spin-offs of REITs and the IRS’s no-ruling policy on certain other types of cash-rich corporate divisions; and S corporation developments.
• Updated discussion of the options and prospects for fundamental corporate tax reform, including an overview of issues affecting U.S. multinational corporations.
• Reorganized discussion of the continuity of proprietary interest doctrine in tax-free reorganizations.
• Expanded coverage of the § 1202 exclusion for sales of small business stock and compensation issues for S corporation owner-employees.
• Removal of dated and historical materials and more tightly edited cases.