Graduate Program in Taxation

Course Descriptions

REQUIRED COURSES

Corporate Tax examines the taxation of corporations and their shareholders focusing on corporate formation capital structure, nonliquidating distributions, liquidations, reorganizations, and the treatment of tax attributes. 4 credits

Partnership Taxation examines the federal income tax consequences of partnership formation and operation, partnership distributions in cash or in kind, withdrawal from partnerships, sale of partnerships, and sale of partnership interests and assets, including definition of a partnership, special allocations of partnership income and losses, the effect of liabilities and a comparison with similar consequences for S corporations. 3 credits

International Tax focuses on the United States taxation of the international activities of U.S. citizens and corporations and the activities of foreign citizens and corporations in the United States. The course provides a foundation for intensive elective international tax courses offered in the spring semester. 3 credits

Federal Wealth Transfer Tax examines federal estate, gift and generation skipping transfer taxes; property included in the gross estate, including prior transfers with retained powers and interests, property subject to powers of appointment, life insurance, annuities, and jointly owned property; valuation; expenses; marital deduction; and definition of taxable gifts, including transfers in revocable and irrevocable trusts, and gifts to minors. 2 credits

ELECTIVE COURSES

Tax Principles: Characterization focuses on the fundamental concepts of a characterization of realized income, including when realized gain (or loss) is not recognized, when it is capital gain (or loss) and when it is ordinary income. 4 credits

Tax Principles: Timing addresses the fundamental issue of accounting, namely, the time when items of revenue and expense are taken into account. Thus, this is the core tax accounting course. It covers annual accounting, the tax year, accounting methods, asset cost recovery, interest and proxies therefore, and installment sales. 2 credits

Tax Policy and Practice is a course that examines the Internal Revenue Code and the regulations thereunder as a series of public policy choices that facilitate or forestall particular tax planning strategies. The current topic is tax shelters and the more general controversies over form and substance, transparency and opacity. Public officials and private sector tax lawyers visit the course to share their views and strategies. 2 credits

International Tax: Inbound Transactions analyzes the taxation of foreign persons in the United States, including taxation of United States real property interests and withholding on the disposition or acquisition of business interests in the United States; related issues such as choice of entity and sales of goods imported into the United States; and pre-immigration tax planning strategies. 2 credits

International Tax: Outbound Transactions examines the income taxation of investments outside the United States, including controlled foreign corporations, passive foreign investment companies, foreign personal holding companies, indirect foreign tax credits, allocations of deductions, and foreign currency transactions. 2 credits

Financial Products are contractually-defined interests in business entities that are neither debt nor equity, although they may have certain features of each.  Taxation of these financial products is subject to substantial uncertainty and complexity.  This course explores the tax issues relating to a range of swaps and derivatives and other contractually-defined interests.  2 credits

Taxation of International Transactions offers experience in tax planning by applying international tax principles to specific types of cross-border transactions. 2 credits

Taxation of International Financial Institutions and Financing Transactions considers the special provisions applicable to cross-border financial transactions. 2 credits

Transfer Pricing and Tax Treaties considers the United States’ bilateral tax treaties as well as alternative provisions commonly adopted by other nations’ bilateral treaties with third countries. It also examines transfer pricing issues. 2 credits

Advanced Corporate Tax explores the tax treatment of corporate tax attributes, provides an introduction to consolidated returns, and considers certain tax issues that arise in bankruptcy.
2 credits

Federal Tax Procedure covers major aspects of tax procedure, tax controversy, and tax dispute resolution. It also includes an in depth analysis of the tax litigation process, with particular reference to the United States Tax Court. The analysis encompasses the organization and jurisdiction of the courts, choice of forum, pleadings, problems in major cases (such as those involving transfer pricing), partnership litigation, the trial process (particularly with respect to discovery, stipulations of facts, burden of proof, and evidentiary questions), briefs, the decisional process, post-trial activity (including attorney’s fees and appeals). 2 credits

Bankruptcy Tax deals with the intersection of tax and bankruptcy law in the bankruptcies of individual and corporate taxpayers as well as of pass through entities. Topics include cancellation of indebtedness, priority and discharge of federal and state tax claims, and the preservation of tax attributes. 2 credits

Commerical Lending will focus on secured syndicated loans, including an analysis of commitment letters, guarantees, security agreements, subordination agreements and multi-creditor loan agreements. Emphasis will be placed on covenants and corporate structure by consideration of hypotheticals of substantial complexity. Asset-backed finance techniques using special purpose companies will be considered. 2 credits

Federal Tax Planning offers intensive consideration of the tax planning issues that arise in closely-held businesses, focusing on tax and related corporate and securities law issues that arise during the life cycle of the business. Students prepare papers proposing solutions to specific problems. 2 credits

Taxation of Exempt Organizations analyzes the rationales for exemption from taxation and the technical provisions applicable to various types of exempt organizations. The course focuses on particular activities of exempt organizations, including political campaign activities, legislative lobbying, and commercial activities, including joint ventures with taxable entities and conversion from exempt to taxable or taxable to exempt status. 2 credits

Pensions and Deferred Compensation explores the regulation and tax consequences of private pension plans and deferred compensation. Central to this study will be the tax, labor, and trust law principles of the Internal Revenue Code, the Employee Retirement Income Security Act, and related statutory and regulatory schemes. 2 credits

Income Tax of Trust and Estates studies the income taxation of estates, trusts, and their beneficiaries; distributable net income; distribution deductions for simple trusts, complex trusts and estates; distributions in kind; the planning of funding marital trusts; post-mortem estate planning and the throwback rules; taxation of trusts for minors; charitable and foreign trusts; assignment of income; income in respect of a decedent; the grantor trust rules; and income tax basis problems. 2 credits

Estate Planning takes a practical approach to the estate planning process, analyzing typical fact patterns encountered in practice. Planning for younger families, affluent retirees, and owners of family businesses is discussed, and ethical considerations, such as conflicts that arise from dual representation of husband and wife, are also considered. 2 credits

State and Local Taxation examines the taxing jurisdiction of state and local governments in the federal system of the United States, with particular attention to efforts to avoid double taxation and efforts to prevent the use of state or local taxing authority to impede interstate commerce in contravention of the United States Constitution. 2 credits