Custom Taxes & Business Strategy (UNC-KF)
by Erickson
ISBN: | Copyright 2024
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| Taxes and Business Strategy, 6e (pg. 1.1-1) | |
| Chapter 1: Introduction to Tax Strategy (pg. 1.1-1) | |
| 1.1 Themes of the Book (pg. 1.1-1) | |
| Taxing Authority as Investment Partner (pg. 1.1-2) | |
| The Importance of a Contractual Perspective (pg. 1.1-4) | |
| 1.2 Why Do Tax Rules Influence Before-Tax Rates of Return and Investment Decisions? (pg. 1.1-4) | |
| Implicit Taxes and Tax Clienteles (pg. 1.1-5) | |
| Tax Planning as a Tax-Favored Activity (pg. 1.1-6) | |
| Why Study Tax Planning? (pg. 1.1-6) | |
| 1.3 Intended Audiences for this Book (pg. 1.1-7) | |
| Summary of Key Points (pg. 1.1-9) | |
| Appendix 1.1: Overview of Calculation of U.S. Income Tax Liability (pg. 1.1-10) | |
| Questions (pg. 1.1-11) | |
| Exercises (pg. 1.1-12) | |
| Tax-Planning Problems (pg. 1.1-12) | |
| References and Related Works (pg. 1.1-13) | |
| Chapter 2: Tax-Planning Fundamentals (pg. 1.2-1) | |
| 2.1 Types of Income Tax Planning (pg. 1.2-3) | |
| Converting Income from One Type to Another (pg. 1.2-3) | |
| Shifting Income from One Pocket to Another (pg. 1.2-4) | |
| Shifting Income from One Time Period to Another (pg. 1.2-5) | |
| 2.2 Restrictions on Taxpayer Behavior (pg. 1.2-6) | |
| Economic Substance, Business Purpose, and Substance over Form (pg. 1.2-6) | |
| Constructive-Receipt Doctrine (pg. 1.2-8) | |
| Related-Party versus Arms-Length Contracts (pg. 1.2-9) | |
| Assignment-of-Income Doctrine (pg. 1.2-9) | |
| 2.3 The Legislative Process and Sources of Tax Information (pg. 1.2-10) | |
| Primary and Secondary Authorities (pg. 1.2-10) | |
| The Legislative Process (pg. 1.2-10) | |
| Regulations and Revenue Rulings that Result from the Passage of a Tax Act (pg. 1.2-11) | |
| International Rules Applicable to U.S. Companies (pg. 1.2-12) | |
| The Role of Judicial Decisions (pg. 1.2-12) | |
| Secondary Authorities (pg. 1.2-12) | |
| Summary of Key Points (pg. 1.2-13) | |
| Appendix 2.1: Sources of Information on Tax Legislation (pg. 1.2-14) | |
| Appendix 2.2: More Detailed Examples of Tax Planning (pg. 1.2-15) | |
| Questions (pg. 1.2-16) | |
| Exercises (pg. 1.2-16) | |
| Tax-Planning Problems (pg. 1.2-17) | |
| References and Additional Readings (pg. 1.2-19) | |
| Chapter 3: Returns on Alternative Savings Vehicles (pg. 1.3-1) | |
| 3.1 Intertemporally Constant Tax Rates (pg. 1.3-2) | |
| Review of Compound Interest (pg. 1.3-3) | |
| Investments in Savings Vehicles I and II (pg. 1.3-4) | |
| Hybrid Savings Vehicles (pg. 1.3-6) | |
| Differences in After-Tax Accumulations in Savings Vehicles I and II as a Function of Pretax Rates of (pg. 1.3-6) | |
| Investments in Savings Vehicle III (pg. 1.3-6) | |
| Comparison of Savings Vehicles II and III (pg. 1.3-7) | |
| Investments in Savings Vehicle IV (pg. 1.3-7) | |
| Investments in Savings Vehicle V (pg. 1.3-8) | |
| Investments in Savings Vehicle VI (pg. 1.3-9) | |
| Savings Vehicle VII (pg. 1.3-10) | |
| Dominance Relations and Summary Comments (pg. 1.3-11) | |
| 3.2 Changes in Tax Rates Over Time (pg. 1.3-12) | |
| 3.3 More on Pension Plans (pg. 1.3-13) | |
| Traditional Deductible IRAs (pg. 1.3-14) | |
| Nondeductible IRAs (pg. 1.3-14) | |
| Roth IRAs (pg. 1.3-14) | |
| Comparison of the Deductible and Roth IRAs-New Contributions (pg. 1.3-14) | |
| Comparison of the Deductible and Roth IRAs-the Conversion Decision (pg. 1.3-16) | |
| Summary of Key Points (pg. 1.3-18) | |
| Questions (pg. 1.3-19) | |
| Exercises (pg. 1.3-19) | |
| Tax-Planning Problems (pg. 1.3-21) | |
| References and Additional Readings (pg. 1.3-22) | |
| Chapter 5: Choosing the Optimal Organizational Form (pg. 1.5-1) | |
| 5.1 Organizational Forms for Producing Goods and Services (pg. 1.5-3) | |
| Data on Partnerships and LLCs (pg. 1.5-4) | |
| Data on Corporations (pg. 1.5-7) | |
| 5.2 Computation of After-Tax Returns To Pass-Through and Non-Pass-Through Forms of Organization (pg. 1.5-8) | |
| 5.3 Start-Up Enterprises: Decision Factors, Expectations, and Observed Data (pg. 1.5-11) | |
| 5.4 Changing Preferences for Organizational Forms Induced by Tax-Rule Changes (pg. 1.5-13) | |
| The Required Before-Tax Rates of Return on Corporate and Partnership Activities (pg. 1.5-13) | |
| The Required Rate of Return on Stocks in the Presence of Dividends (pg. 1.5-15) | |
| The Effective Annualized Tax Rate on Shares: ts (pg. 1.5-16) | |
| Required Before-Tax Rate of Return: Corporations versus Partnerships: R*c (pg. 1.5-17) | |
| Post TRA 1986 (1987, 1988-1990) (pg. 1.5-18) | |
| Further Analysis of the 2003 Tax Act (pg. 1.5-19) | |
| The TCJA, Changing Organizational Form, and Tax Planning (pg. 1.5-22) | |
| Progressive Personal Income Tax Rates, tp and tcg (pg. 1.5-22) | |
| 5.5 Other Organizational Forms Through Which to Organize Production Activities (pg. 1.5-22) | |
| Summary of Key Points (pg. 1.5-24) | |
| Appendix 5.1: Dividend Imputation in the Corporate Form (pg. 1.5-25) | |
| Appendix 5.2 (pg. 1.5-27) | |
| Questions (pg. 1.5-28) | |
| Exercises (pg. 1.5-29) | |
| Tax-Planning Problems (pg. 1.5-29) | |
| References and Additional Readings (pg. 1.5-31) | |
| Chapter 6: Corporations: Formation, Operation, Capital Structure, and Liquidation (pg. 1.6-1) | |
| 6.1 Corporate Formation (pg. 1.6-2) | |
| 6.2 Taxation of Corporate Operations (pg. 1.6-3) | |
| Book-Tax Differences: Taxable Income versus GAAP Income (pg. 1.6-4) | |
| Net Operating Losses (pg. 1.6-4) | |
| Gains and Losses and Tax Basis (pg. 1.6-5) | |
| Capital Gains and Losses (pg. 1.6-5) | |
| Section 1231 Assets (pg. 1.6-5) | |
| Dividends Received Deduction (pg. 1.6-6) | |
| Consolidated Tax Returns (pg. 1.6-6) | |
| 6.3 Possible Tax Benefits of Leverage in Firms’ Capital Structures (pg. 1.6-6) | |
| Theory of the Tax Benefits of Leverage (pg. 1.6-7) | |
| Empirical Work on the Tax Benefits of Leverage (pg. 1.6-8) | |
| 6.4 Debt-Equity Hybrids (pg. 1.6-9) | |
| Traditional Preferred Stock (pg. 1.6-9) | |
| Trust Preferred Stock (pg. 1.6-10) | |
| Zero-Coupon Bonds (pg. 1.6-12) | |
| 6.5 Taxation of Distributions and Share Repurchases (pg. 1.6-14) | |
| The Concept of Earnings and Profits (pg. 1.6-15) | |
| Special Kinds of Distributions (pg. 1.6-16) | |
| Taxation of Share Repurchases (pg. 1.6-17) | |
| 6.6 Tax Planning Using the Tax Rules for Distributions and Share Repurchases (pg. 1.6-18) | |
| 6.7 Taxation of Liquidations (pg. 1.6-18) | |
| Parent-Subsidiary Liquidations (pg. 1.6-19) | |
| Summary of Key Points (pg. 1.6-19) | |
| Questions (pg. 1.6-20) | |
| Exercises (pg. 1.6-20) | |
| References and Additional Readings (pg. 1.6-21) | |
| Chapter 10: Multinational Tax Planning (pg. 1.10-1) | |
| 10.1 Fundamental Issues in International Tax (pg. 1.10-1) | |
| 10.2 Increasing Pressures on Tax Systems Posed by Cross-Border Commerce (pg. 1.10-2) | |
| 10.3 Overview of International Taxation (pg. 1.10-4) | |
| Operating as a Branch, Partnership, or a Foreign Subsidiary (pg. 1.10-5) | |
| Foreign Tax Credits and the Participation Exemption (pg. 1.10-5) | |
| Country-by-Country FTC Limitations (pg. 1.10-7) | |
| Separate Basket Limitations (pg. 1.10-8) | |
| 10.4 Base Erosion and Income Shifting Across Countries (pg. 1.10-8) | |
| Transfer Pricing (pg. 1.10-8) | |
| Subpart F Income and Controlled Foreign Corporations (CFCs) (pg. 1.10-9) | |
| Congress BEATs the (allegedly) GILTI (pg. 1.10-9) | |
| Individuals Avoiding U.S. Taxation (pg. 1.10-10) | |
| 10.5 How Taxes Affect the Location and Structure of Investments (pg. 1.10-11) | |
| A Tax Holiday for Repatriations (pg. 1.10-12) | |
| Inversion Transactions (pg. 1.10-12) | |
| Summary of Key Points (pg. 1.10-15) | |
| Questions (pg. 1.10-16) | |
| Exercises (pg. 1.10-16) | |
| References and Additional Readings (pg. 1.10-18) | |
Merle Erickson
Merle Erickson is Professor of Accounting at the Booth School of Business at the University of Chicago.
Professor Erickson has taught “Taxes and Business Strategy” in the Booth MBA program for more than twenty years. Erickson earned a bachelor's degree in accounting from Rockhurst College in 1987, an MBA in 1989 from Arizona State University, and a PhD in accounting from the University of Arizona in 1996. He joined the Chicago Booth faculty in 1996.
He has published numerous articles in a variety of top academic journals (e.g., Journal of Accounting Research, The Accounting Review, Journal of Accounting and Economics,). He has been given several awards from the American Taxation Association for his research and teaching. He has received the Outstanding Manuscript Award (twice) as well as an award for teaching innovation. He also has been named one of BusinessWeek's Outstanding Faculty at the University of Chicago. He is the author/editor of the casebook, Cases in Tax Strategy. In addition to teaching graduate students at Chicago Booth, Erickson has taught courses to Morgan Stanley, Merrill Lynch, General Electric Capital Corporation, Baker McKenzie, Andersen Consulting, Accenture, CareerBuilder, and the IMCA (Investment Management Consultants Association) among others. From 2005-2011, he served as a co-editor of the Journal of Accounting Research.
Over the course of his career, Erickson has consulted on complex GAAP and tax accounting issues (e.g., debt versus equity, FIN 48 and ASC 740 related issues, intercompany accounting and consolidation, employee stock option accounting) in a variety of contexts (e.g., bankruptcy, mergers and acquisitions, inversions, structured finance, investment planning, cross border and intercompany financing, tax sharing agreements, and various types of tax advantaged transactions). His clients have included, among others, the U.S. Department of Justice, the Internal Revenue Service, Fortune 500 companies in various industries, international financial institutions including investment banks, law firms, accounting firms, and individual taxpayers.
In addition to his scholarly activities, Erickson is an avid fisherman. He received the Angler Award from the Billfish Foundation in 2003 for releasing the most striped marlin worldwide that year.
| Taxes and Business Strategy, 6e (Erickson, Hanlon, Maydew, Shevlin) | |
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Errata Last Updated: Nov 5 2021 |
Corrections to identified errors in the text. |
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