Index

• Pages: 479-486
• Author: Howard E. Abrams,Don A. Leatherman,Thomas J. Brennan

479

INDEX

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References are to Pages

ACCUMULATED EARNINGS

TAX

Generally, 395 et seq.

Burden of proof, 399

Computation, 400

Objective tests, 397

Personal holding company tax

computations compared, 406

Publicly held corporations, 396

Purpose of accumulation

Generally, 396

Burden of proof, 399

Subjective tests, 397

ACQUISITIONS OF CORPORATE

INTERESTS

Generally, 235 et seq.

Adjusted grossed-up basis (AGUB),

255

Aggregate deemed sales price

(ADSP), 266

Allocations by buyer and seller, 239

Asset purchases, 237

Bootstrap acquisitions, 167

Control test, 33

Debt financing, tax implications, 268

Elections under Section 338, 243

Expenses, deductibility, 267

Golden parachutes, 273

Greenmail, 273

INDOPCO test of expense

deductions, 267

Leverage, tax implications, 268

Net operating loss (NOL) carrybacks,

271

Original issue discount (OID)

financing, 272

Payment in kind (PIK) bond

financing, 272

S corporation acquisitions, 435

Stock purchases, 241

Trafficking in high NOL

corporations, 368

ADJUSTED GROSS INCOME

Generally, 75

AGGREGATE VS ENTITY

BUSINESS ENTITY

STATUS

Generally, 73, 417

Hybrid entities, 214

ALLOCATIONS

See also Assignments of

Income, this index;

Reallocations of Income,

this index

Acquisition agreement provisions,

238

Basis, 67

ASSET PURCHASES

Generally, 235

See also Acquisitions of

Corporate Interests, this

index

S corporation acquisitions, 435

ASSIGNMENTS OF INCOME

Generally, 69, 83

S corporations, 454

ASSOCIATIONS

Corporate tax treatment, 77

AT-RISK RULES

S corporations, 451

ATTRIBUTES, COMBINING

Generally, 367 et seq.

See also Net Operating Losses,

this index

Consolidated Groups, 380 et seq.

BAILOUTS

Generally, 201 et seq.

BASE, TAX

Generally, 73

BASIS

Adjusted grossed-up basis (AGUB),

255

Allocations, 47

Contributed property, 53

Property distributions, corporate

basis, 125

S corporation basis rules, 447

BOOT

Generally, 30

Preferred stock subject to § 351, 35,

53

Reorganization distributions, 349,

360

Section 351 boot, 30