Open Educational Resources

This book is the 8th edition of a basic income tax text. This edition incorporates the Tax Cuts and Jobs Act of 2017. It is intended to be a readable text, suitable for a three-hour course for a class comprised of law students with widely different backgrounds. The text integrates several of the CALI drills that Professor James Edward Maule (Villanova University) prepared. A teacher manual is also available to instructors by logging into CALI.

This third edition casebook is a basic corporate tax text. It is intended to be suitable for a three-hour law school course. The text is designed to be accessible to law students from widely different backgrounds. However, the material assumes that students already have taken a course in basic income tax. The casebook includes links to numerous CALI tutorials allowing students to assess their knowledge throughout the course.

Available via SSRN: Federal Tax Procedure is the book for originally prepared for a course on Tax Procedure taught by Adjunct Professor Townsend at the University of Houston School of Law (through the Fall of 2015). The book and related materials contain text discussion, relevant Code Sections, and certain cases designed to encourage students to think about the Tax Procedure process. The book is in electronic format (Adobe Acrobat PDF format) and is in two versions – (1) a Student Edition (no footnotes); and (2) a Practitioner Edition (same as Student Edition but including the footnotes). This is the Student Edition. Both versions are available on Mr. Townsend's SSRN web page. Mr. Townsend's practice is to update the text PDF once a year in the summer to permit the book to be used in the following academic year. Updates and additional matters related to the book may be found on Mr. Townsend's Federal Tax Procedure Blog.

This book attempts the simplest possible introduction to an intricate body of law. Any “simplified” description of the rules of partnership taxation would be so misleading as to be useless. We have therefore tried to make the subject accessible not by paraphrasing the rules, but by including numerous illustrations that are as straightforward as possible. The text focuses on simple partnerships holding few assets and engaging in routine transactions. It places the rules in context by pointing out the purposes of the statute and regulations and presenting background information about practical matters such as how partnerships maintain capital accounts and how nonrecourse financing works. Using many examples, it then shows the operation of the rules in everyday cases encountered by practitioners. This is not a reference book: many interesting and difficult issues have been ignored. Some matters, such as the application of § 736 to noncash distributions and the taxation of tiered partnerships, are not discussed at all. Most of the points that are addressed, however, are discussed at considerable length. Changes may be on the horizon; as this edition is going to press, tax professionals are grappling with understanding and implementing 2017 tax legislation, which included a reduction to the tax rate for some types of pass-through income. Numerous proposed regulations have been issued in recent years, and new regulatory projects interpreting the recent legislation are likely. Our goal has been to give students background material and illustrations so that they can begin to understand and work with a statute that was drafted for (and by) experienced practitioners and so that they can be prepared to make sense of any future changes. Most chapters end with a section comparing the tax treatment of partners with that of the shareholders of S corporations. Many students encountering partnership taxation for the first time have already studied subchapter S. We expect that an examination of some of the basic differences between subchapters S and K should help those students understand both subjects.

This chapter’s objective is to raise interesting tax ethics issues in practical contexts. There are 42 notes and questions to prompt and guide discussions, and primary source materials to inform the discussions (e.g., cases, IRC provisions, and Circular 230 excerpts). A teacher manual is also available by logging into CALI.

This book is a useful companion to law students taking a course in this area. It can also serve as a course book that will provide an introduction to the subject as a prelude to applying the principles to a set of problems. This complex topic has been made comprehensible to readers who are not yet conversant with the area and is a valuable supplement to a casebook or set of problems. The book discusses the crucial issues of corporate taxation and provides numerous examples illustrating how the various provisions operate.

The eighth edition of this popular student supplement retains the cradle-to-grave ordering of prior editions and is updated to reflect changes made by the Tax Cuts and Jobs Act as well as other recent changes in the law. In addition to using a “cradle-to-grave” approach to corporate taxation, the book features a discussion of taxable and tax-free corporate acquisitions and penalty provisions. It also surveys the tax treatment of S corporations and (briefly) consolidated groups. Full of examples with explanations of both how and why the system works as it does, this book can be used alongside any standard casebook. It may also be used as a primary text for those who emphasize the problem method and have developed their own problem set.

In addition to incorporating new law and all inflation adjustments, this 2021 edition incorporates new charts pertaining to economic and tax data, including December 2019 CBO charts showing that income inequality between 2015 and 2020 (with the Tax Cuts and Jobs Act enacted in 2017) worsened after taxes and transfers than before taxes and transfers are taken into account. This textbook is not intended to be an exhaustive treatise; rather, it is intended to be far more useful than that for beginning tax law students by equipping the novice not merely with unmoored detail but rather with a rich blueprint that illuminates the deeper structural framework on which that detail hangs (sometimes crookedly). Chapter 1 outlines the conceptual meaning of the term income for uniquely tax purposes and examines the Internal Revenue Code provisions that translate this construct into positive law. Chapter 2 explores various forms of consumption taxation because the modern Internal Revenue Code is best perceived as a hybrid income-consumption tax that also contains many provisions that are inconsistent with both forms of taxation. Chapter 3 then provides students with the story of how we got to where we are today, important context about the distribution of the tax burden, the budget, and economic trends, as well as material on ethical debates, economic theories, and politics as they affect taxation. Armed with this larger blueprint, students are in a much better position to evaluate the myriad pieces that follow throughout the remaining 18 chapters. For example, they are in a better position to appreciate how applying the income tax rules for debt to a debt-financed investment afforded more favorable consumption tax treatment creates tax shelter problems. Stated another way, they can better appreciate how the tax system can sometimes be used to generate (or combat) unfair and economically inefficient rent-seeking behavior.

This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Fourth Edition is divided into three sections: common elements of international taxation for both inbound and outbound taxation, inbound U.S. taxation, and outbound U.S. taxation. Special attention is focused on base erosion and profit shifting strategies and the resulting complexity that has been added to the U.S. tax regime to address this phenomenon in the inbound and outbound context. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.

The book is not organized according to the chronological life of a corporation. Instead, the book begins by examining the tax treatment of a withdrawal of property from an existing corporation. The reason for choosing that organization is that the concepts embodied in such topics as dividends, earnings and profits, and stock redemptions are the fundamental building blocks on which the more complex provisions of corporate taxation rest. The authors explain the technical operation of the various Code provisions and provide numerous examples illustrating how they are applied and how several provisions must be read in concert with each other.

This highly-acclaimed text explains the conceptual basis of federal income taxation. It is designed to help students quickly pull together the entire subject for end-of-semester review and provide perspective about where a topic fits within the federal income tax scheme. While focusing on the present income tax, the text provides an explanation of the often-discussed consumption tax and contrasts the two taxes in a note at the end of the volume. The new edition reflects developments since the thirteenth edition, including many changes made by the Tax Cuts and Jobs Act of 2017—the most significant federal tax legislation in more than thirty years.

The new edition of Principles of Tax Policy explains the essential building blocks of the American tax system clearly and concisely, including the effects of changes adopted in the Tax Cut and Jobs Act of 2017. Chapters range from the political process to individual and corporate income taxes, Social Security and other payroll taxes, state and local budgeting, and international tax planning. Each chapter opens with a brief description of the covered policy topic, providing a synopsis of the current state of the law. Ample footnotes provide easy access to articles and standard reference works allowing readers to dig deeper on their own.

The perfect companion for students in law school tax courses and practitioners seeking a helpful introduction, this popular reference has been completely updated to reflect recent developments. Like prior editions, it includes analysis of cases and concepts from the leading casebooks on federal income tax, complete with explanations, diagrams and flow charts. The book includes extensive treatment of the time value of money issues.