Courses

• LAW TX 933: Introduction to Corporate Tax
  Income tax considerations relating to transfers of assets and liabilities to a corporation (during incorporation and otherwise), non-liquidating distributions, stock redemptions, related party stock purchases and corporate liquidations. Includes an overview of the treatment of a corporate shareholder versus other shareholders. Co- or prerequisites: Federal Income Tax I and Federal Income Tax II.
• LAW TX 934: Estate Pl.-Adv.
  This course description is currently under construction.
• LAW TX 935: Estate Planning
  This course will examine in depth the theoretical and practical aspects of a variety of estate planning strategies currently being used in the real world. The primary focus of the course will be on federal income, estate, gift, and generation skipping transfer tax issues which arise in the estate planning context, although other planning issues, including professional ethics, will also be considered. The course will use case studies of specific tax driven planning strategies, including grantor trusts, marital deduction trusts, post-mortem planning, and planning for incapacity. Prerequisites or corequisites: Federal Income Taxation I and Estate and Gift Taxation.
• LAW TX 936: Taxation of Bankruptcies and Workouts
  Study of the tax and opportunities arising in bankruptcy and nonbankruptcy workouts of individuals, partnerships, and corporations. Topics include cancellation of indebtedness income from the reduction or renegotiation of debt, gain or loss recognition on foreclosures and similar property transfers, restrictions on net operating loss carryovers, special tax consequences of the restructuring of partnership debt and equity, the taxation of the bankruptcy estate and its owners and creditors, and trust fund tax penalties on officers, directors, and other individuals. Prerequisites or corequisites: Introduction to Corporate Tax and Partnership Tax I.
• LAW TX 937: Taxation of Trusts and Fiduciaries
  Income tax consequences arising upon the death of a decedent and special income tax treatments of estates, trusts, and fiduciaries. Topics include determination of gross income and allocation between the decedent and the estate or trust; special problems with income in respect of a decedent; separate and conduit taxation of estates and trusts; allocation of tax attributes between an estate or trust and its beneficiaries; grantor trust rules, and other topics. Prerequisite: Federal Income Taxation I.
• LAW TX 939: International Tax II- Outbound US Taxation, the Foreign Tax Credit and Subpart F
  This course will examine in some detail two fundamental but most important areas of the U.S. taxation of U.S. corporations' foreign operations. This course is designed for those students who are interested in practicing in the international tax area or who are interested in exploring in considerable detail two on the Internal Revenue Code's more complex statutory regimes. This course will include an in-depth analysis of the rules relating to the foreign tax credit, including basic sources of income and allocations of deductions (particularly, interest expense), with emphasis on the determination of the deemed paid credit, the overall and separate limitations and the look-through and foreign loss rules. The second part will address in detail the anti-deferral provisions under Subpart F of the IRC, including the definition of U.S. shareholder and controlled foreign corporation, the determination of the various types of subpart F inclusions, and the effect of partnership and disregarded entities on the application of these rules. Notes: Limited enrollment. Grade based on a mid-term examination, a final examination, and class participation. Prerequisite or corequisite: International Tax I
• LAW TX 940: Partnership Tax II
  A continuation of Partnership Tax I, focusing on a more in depth study of complex areas of partnership taxation. Topics include allocation of liabilities, maintenance of capital accounts and special allocations of income and loss, allocations with respect to contributed property; complexities in partnership distributions such as disguised sales, distributions with respect to contributed property, mixing-bowl transactions and marketable securities and examination of anti-abuse regulations and judicial action on abusive transactions. This course will follow a problem approach with applications of complex concepts to real life situations. Prerequisites: Federal Income Taxation I, Federal Income Taxation II, and Partnership Tax I.
• LAW TX 944: Structuring Intellectual Property Ownership
  Intellectual Property is the engine for the modern world economy. This course will look at US and international tax strategies implemented by individuals and companies owning IP to minimize the tax costs and maximize the economic benefits. The course will examine the tax consequences, and appropriate strategies, for developing intellectual property, acquiring intellectual property from another party, transferring intellectual property rights in the most cast effective manner. The course will have a strong emphasis on international tax, including the effects of bilateral tax treaties, related party transaction rules (such as Code 482), U.S. rules governing transfer of intellectual property out of the United States (Code 367), cost sharing arrangements under Code 482, and other sophisticated transactional issues such as charitable contributions and intellectual property in order to claim contribution deductions. Prerequisite: International Tax I: Taxation of International Trade Investment and Finance. Recommended: Taxation of Intellectual Property I.
• LAW TX 946: Real Estate Taxation
  An in depth examination of the federal income tax aspects of real estate transactions. Topics include acquisition issues, use of various forms of debt and equity financing, calculation of initial basis, allocation of purchase price and depreciation issues; disposition issues, including calculation of amount and character of gain or loss and installment sales rules, tax deferred transactions, including like-kind exchanges and involuntary conversions.
• LAW TX 949: Taxation of Financial Products: Principles and Application
  An in-depth study of the "nuts and bolts" of the taxation of financial products. The course, which is designed to provide a hands-on knowledge-base for current and aspiring financial-services tax professionals, will have three main components. It will begin with a comprehensive examination of the taxation of debt instruments, with an intensive review of original issue discount and related rules. Next, it will turn to the taxation of derivatives, including options, forwards, futures, swaps and variable annuities. It will conclude with a review of the federal government's response to perceived abuses involving financial instruments, covering areas including constructive sales, constructive ownership transactions and the tax shelter regulations. Some use of a financial calculator or spreadsheets will be required. The course is intended to complement TX 917 Taxation of Financial Products: Policy and Theory and may be taken either prior or subsequent to that class or on a stand-alone basis. Pre or Co-requisites: Federal Income Taxation I & II.
• LAW TX 950: Tax Aspects of Charitable Giving
  Charitable gift planning has long been a crucial component in wealth management and estate planning. It remains an important factor in the "tool box" of estate and tax professionals. While humanitarian commitments remain the primary motivating force behind private philanthropy, the tax benefits associated with charitable strategies and techniques have assumed greater importance as our system of taxation has grown increasingly complex. This course will examine the federal tax implications (income tax, gift tax, estate and generation skipping transfer tax, and capital gains tax) of key strategies associated with charitable gift planning for incorporation into the overall estate plan. Topics covered will include types of charitable entities, requirements of a charitable gift, charitable alternatives (private foundations, donor advised funds and supporting organizations), split interest transfers (charitable remainder and lead trusts), bargain sales, gifts of complex assets, and testamentary transfers. Case studies will be used to illustrate optimal intervivos and testamentary planning for creating flexibility while avoiding pitfalls. Pre-requisites: Federal Income Tax I, Federal Income Tax II.
• LAW TX 951: US Transfer Pricing
  This course undertakes a detailed examination of the US transfer pricing rules, policies and procedures. It will only casually address issues in other jurisdictions- transfer pricing rules in strongly OECD jurisdictions like Canada, the United Kingdom and Australia will be considered only in a contrasting manner to provide context. In addition, the transfer pricing rules in customs and those in the VAT (EU and elsewhere) will similarly be considered only where they provide contrast to the US rules.
• LAW TX 952: EU VAT
  This course considers the details of the world's leading Value Added Tax system, the E.U. VAT. Students should expect to acquire a good grounding in the major legal instruments of the community (regulations, directions and decisions) which have binding effect on the member states as well as the recommendations and opinions which do not. Case law will be considered primarily from the leading decisions of the European Court Justice, although an occasional decision or two from domestic courts will be included. Major developments in the E.U. VAT are expected to be covered, including: (1) the adoption of the "reverse charge" mechanism as a response to widespread carousel fraud, (2) the inclusion of a transfer pricing regime under Rationalization Directive, and (3) proposals for major changes in the place of supply rules in services and intangibles.
• LAW TX 953: Inbound International Taxation
  This course will cover the U.S. tax rules applicable to taxation of income from U.S. (and sometimes foreign) sources received by corporations and individuals that are non-residents of the United States. In some cases, such income will be derived from passive investments and be in the form of dividends, interest, rents, or royalties. In other cases, the income will arise from active business activities. The course will address the concept of residence and entity classification, the U.S. source of income rules, the U.S. withholding tax rules (including the obligations of withholding agents) with respect to non-business income, the types of activities that can generate a "trade or business" (tax nexus) in the U.S., the U.S. rules for determining income effectively connected with a U.S. trade or business and thus taxable in the U.S., the branch profits tax, FIRPTA (foreign investment in U.S. real property) and the U.S. rules applicable to financing U.S. operations owned by non-U.S. taxpayers Finally, we will address the impact of tax treaties on the taxation of income of non-residents. This course will be of interest to students who will represent foreign resident taxpayers with economic operations in the United States.
• LAW TX 955: Taxation of Intellectual Property
  Intellectual property- from sophisticated aerospace technology to computer software and web applications to music and video rights- is one of the most important, challenging, and sophisticated areas of modern commerce. However, because the IP revolution has occurred in only the last 25 years, many of the traditional principles of income taxation are not easily applied to IP assets. This course will explore the tax aspects of creating intellectual property, buying intellectual property, exploiting IP through leases and licenses, and strategies for selling valuable IP rights with the best tax results. The course will also explore important international tax issues, including the so called "migration" of IP offshore, cost-sharing arrangements, and other mechanisms that seek to "locate" IP and the associated tax liabilities in tax-favorable jurisdictions. The course will teach the tax differences between copyrighting and patenting a software program, the right and wrong ways to license and sell a trademark, and the mechanisms for turning a "license" into a "sale" and thereby converting ordinary income into capitol gains.
• LAW TX 958: International Estate Planning
  The course will cover international estate planning from two perspectives: (1) U.S. citizens residing outside of the U.S. or owning assets located outside of the U.S.; and (2) foreign citizens residing in the U.S. or transferring assets in or to the U.S. U.S. gift and estate tax laws applicable to both situations will be studied in depth in a practice-oriented manner. Planning techniques and vehicles utilized in international estate planning will be explored, in particular trusts and the special U.S. income tax rules applicable to foreign trusts with U.S. beneficiaries and off-shore U.S.-grantor trusts. The impact of non-U.S. transfer taxes and tax treaties will be considered, as well as non-tax foreign laws impacting on international estate planning. The course will also cover the U.S. tax and estate planning issues applicable to "mixed marriages" where one spouse is a U.S. citizen and the other is a non-U.S. citizen, and multi-jurisdiction situations of gifts or bequests from non-U.S. donors or decedents to U.S. beneficiaries. Finally, the course will also consider cultural and ethical issues peculiar to the area of international estate planning. Prerequisite or corequisite: Estate and Gift Tax, Estate Planning
• LAW TX 959: Making Tax Law
  The course explores how U.S. tax law is made in order to provide context and perspective for interpreting the various provisions of the tax law. It examines how considerations of tax policy, tax politics and tax administration contribute to the development of law through the legislative process, the promulgation of regulations and other administrative guidance, and the negotiation and ratification of tax treaties, as well as interactions and judicial evaluations of all of the above. In other words, the course explores what happens on the road to tax law and what causes those twists and turns. It necessarily discusses issues of tax policy, but the principal focus is on process. We will use traditional cases, legislative documents, and other materials. Pre or corequisite: Federal Income Taxation I
• LAW TX 960: Executive Compensation- Advanced
  In this course we will take an in-depth look at the major Code provisions applicable to executive compensation. We will spend considerable time analyzing the regulations and other guidance under Code Sections 409A, 457, 162 and 280G. We will also consider recent changes to executive compensation rules implemented through recent bailout legislation. This will be a discussion intense course. Students will be expected to carry on high level discussions based on real-world examples. Students should have completed the Introductory Executive Compensation course or demonstrate ability beyond a basic level of knowledge in this subject area.
• LAW TX 961: Fed Inc Tax
  
• LAW TX 962: Intl Tax