The eighth 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 eighth edition include: Coverage of all significant developments since the last edition, including the impact of changing tax rates on corporate-shareholder transactions; regulations on the basis consequences of dividend-equivalent redemptions, allocation of basis in various corporate-shareholder transactions, i?? 336(e) elections, "all cash" D reorganizations, and the treatment of hot stock in corporate divisions; and codification of the economic substance doctrine, the accompanying strict liability penalty, and their implications for transactional planning. A discussion of the design options and prospects for fundamental corporate tax reform. A revised chapter on capital structure with a new case and expanded coverage of hybrid instruments and a Note on the differences between financial and accounting treatment of debt and equity.
Full text of a 2008 published ruling on application of the step transaction doctrine to multi-step acquisitions. Reorganized problem sets on acquisitive reorganizations and corporate divisions, with an emphasis on more efficient coverage in a transactional setting. Pruning of dated materials and some technical minutia, and more tightly edited cases, notes and problems.