Earnings and Profits – The Corporation’s Capacity to Pay Dividends
Contributions to Capital – The Fink Case and the Unitary View of Stock
Assignment of Income and Section 351 – The Hempt Bros. Problem
Installment Obligations in Section 351 – The Peracchi Case
Non‑Qualified Preferred Stock – When Preferred Stock Acts Like Debt
Assumption of Liabilities in Section 351 – Avoiding the Hendler Problem
Boot in Section 351 Transactions – When You Receive More Than Just Stock
The Transferor Group – Who Counts for the 80% Control Test?
Control “Immediately After the Exchange” – The Intermountain Lumber Case
Section 351 – The Tax‑Free Transfer of Property to a Controlled Corporation
Loans to Shareholders – The Bergersen Case and the Problem of Constructive Dividends
Selling Property to Your Own Corporation – The Burr Oaks Trap
Reasonable Compensation – The Menard Presumption
Debt vs. Equity – The Classic Plantation Patterns Case
The Accumulated Earnings Tax – When Your Corporation Saves Too Much
The Personal Holding Company Tax – When Your C Corporation Looks Like an Investment Vehicle
How the TCJA Widened the Corporate‑Individual Tax Gap
The Double Tax on Corporate Income – The Basic Problem
Depreciation Recapture – Sections 1245 and 1250 Explain*
Capital Assets – The Broad Definition and Its Exceptions