Strategic Corporate Tax Planning

JOHN E. KARAYAN, JD, PhD, is a tax attorney with a "Big 8" CPA firm background. Retired from practice to teach, he has remained active outside of academia as a consultant to entrepreneurs and as an expert witness in complex litigation. CHARLES W. SWENSON, PhD, CPA, is Professor of Taxation at the University of Southern California. His professional experience includes being a tax consultant with Pricewaterhouse-Coopers. Winner of several American Taxation Association Awards, Professor Swenson has published extensively in leading journals. JOSEPH W. NEFF, JD, is a Partner with PricewaterhouseCoopers. His expertise in tax planning for entrepreneurs and by managers is summed up by his current position in the firm: the U.S. National Partner in Charge of Middle Market Tax Practice.

INTRODUCTION; PART ONE: Understanding Strategic Tax Planning: A Framework; CHAPTER 1: A Framework for Understanding Taxes; How Are Taxes Important in Decision Making?; Types of Taxes; Basic Principles of Taxation; Sources of Tax Laws; Important Principles and Concepts in Tax Law; Savant Framework; CHAPTER 2: Utilizing the SAVANT Framework to Guide Tax Planning; Strategy; Anticipation; Value-Adding; Negotiating; Transforming; Putting It All Together: SAVANT Concepts Illustrated; PART TWO: Forming the Enterprise; CHAPTER 3: Choosing a Legal Entity: Risk Management, Raising Capital, and Tax Management; Strategy; Anticipation and Timing Issues; Value-Adding; Negotiating; Transforming; Putting It All Together: Applying SAVANT to Entity Choice; Specialized Legal Forms; CHAPTER 4: Financing a New Venture; Internal Financing; External Financing: Debt versus Equity; PART THREE: Operating the Firm; CHAPTER 5: New Products: Development, Promotion, and Advertising; New Products and Product Improvement; SAVANT and Research and Development; CHAPTER 6: Attracting and Motivating Employees and Managers: Company and Employee Tax Planning; Executive Compensation; Nonexecutive Employee Compensation; Perquisites; Pension and Profit Sharing Plans; Current and Deferred Compensation; Limits on Deductibility on Executive Compensation; Stock Options; Management Bonus Plans; Financial Statement/Finance versus Tax Strategy Trade-Offs; Putting It All Together: Applying SAVANT to Executive Compensation; CHAPTER 7: Market Penetration: Operating in Different States; General Principles of State and Local Taxation; Planning with Income Taxes: Manipulation of Plant, Workforce, and Point of Sale Locations; Location Choice: Sourcing versus Production Platforms; Distribution: Planning for Sales and Use Taxes; Lobbying and Tax Abatements; Trade-Offs with Local Tax Incentives: Infrastructure, Government Costs/Subsidies, and Other Local Costs; Putting It All Together: SAVANT Applied to Market Penetration in Other States; CHAPTER 8: Market Penetration: Company and Employee Tax Planning for Operating in Foreign Countries; Some Basics on U.S. Taxation of Overseas Operations; Some Basics on Taxation by Countries Other Than the United States; Tax Treaties; Effective Tax Management; Putting It All Together: Penetrating Foreign Markets from a SAVANT Perspective; CHAPTER 9: Operations Management; Production Design and process Selection; Inventory: Methods of Accounting and Includable Amounts; Strategic Capacity Planning: Plant versus People; Putting It All Together: Operations Management from a SAVANT Perspective; CHAPTER 10: Financing Ongoing Operations and Tax Planning; Operating Earnings; Sale of Operating Assets; Sale of Investments; Short-Term Borrowing; Accounts Receivable; Decrease in Dividends; Stock Dividends; Stock Buybacks; Using Employee Stock Ownership Plans; Receipt of Dividends from Subsidiaries; Putting It All Together: Financing Ongoing Operations from a SAVANT...