The Federal Income Taxation of Corporations, Partnerships, Limited Liability Companies and Their Owners

The 2009 Supplement fully integrates the American Jobs Creation Act of 2004, the Tax Increase Prevention and Reconciliation Act of 2005, the Small Business and Work Opportunity Act of 2007 and the Tax Technical Corrections Act of 2007. The 2009 Supplement also includes new cases, rulings and notes. Highlights include: The addition of the recently decided Supreme Court case Boulware v. United States to the discussion of constructive distributionsAn expanded discussion of the partnership anti-abuse regulationUpdated section 351, 358 and 362 materials reflecting the mandatory step-down in basis of loss property contributed to a corporationUpdated section 734, 743 and 754 materials reflecting the mandatory step-down in partnership inside basis for certain sales of partnership interests and distributions of partnership propertyDiscussion of new regulations clarifying that 40% stock is sufficient consideration to satisfy continuity of proprietary interest in a corporate reorganization the addition of Revenue Ruling 2008-25 to the discussion of multi-step corporate acquisitions.

Jeffrey L. Kwall, Kathleen and Bernard Beazley Professor of Law, Loyola University Chicago School of Law