Tax Law

  • LAW TX 901: Federal Income Taxation I
    This course presents a general introduction to the fundamentals of federal income tax, emphasizing issues common to individual taxpayers (but not including the federal income tax aspects of the acquisition, ownership, and disposition of property, which are the subject of Federal Income Taxation II). Topics include an overview of the federal tax system; gross income, inclusions, and exclusions; identity of the proper taxpayer; concepts and categories of deductions; and basic timing principles.
  • LAW TX 902: Federal Income Taxation II
    Federal income tax aspects of the acquisition, ownership, and disposition of property. Topics include: 1.Realization and recognition, 2.Basis and amount realized, 3.The effects of debt (including its cancellation), 4.Depreciation and amortization, 5.At risk, not for profit, and passive activity loss deductibility limitations, 6.Capital gains and losses, related party transactions, quasi-capital assets and depreciation recapture, and 7.Deferred payment transactions (original issue discount and installment sales). Prerequisite or corequisite: Federal Income Taxation I.
  • LAW TX 904: Estate and Gift Taxation
    Principle issues of estate and gift taxation. Topics include the definition of taxable gifts and exclusions and deductions; determination of the taxable estate of a decedent including problems with lifetime transfers; valuation issues; deductions from the taxable estate with special emphasis on property passing to a spouse; and transfers with retained interests. Reference is made throughout to planning issues relating to estate and gift taxation and is designed to give both a requisite background for those intending additional study of estate planning and a comfortable familiarity with the subject for those going on to other tax fields.
  • LAW TX 905: ERISA Regulation of Retirement Plans
    Regulation of pension and profit sharing plans by the Internal Revenue Code and Employee Retirement Income Security Act, with particular attention to rules applicable to tax-qualified pension and profit-sharing plans, including rules governing the structure of benefits and taxation of contributions and distributions.
  • LAW TX 906: Tax Aspects of International Business
    Tax aspects of international business transactions, both "inbound" and "outbound", with particular attention to fiscal jurisdiction, the foreign tax credit, allocation of income among affiliated companies, treaties, anti-abuse measures aimed at tax haven operations, information reporting and foreign investment in U.S. securities and real estate.
  • LAW TX 907: Tax Practice & Procedure
    Structure of the U.S. tax system; administration of the Internal Revenue Code by the Internal Revenue Service; ethics of tax practice and the regulation of tax practitioners; study of the administrative processing of tax returns; handling of audits, statutes of limitations, assessment of deficiencies and penalties, claims for refund, hearings before the Appeals Office, closing agreement, tax liens, tax collection procedures and civil and criminal aspects of tax fraud. Introduction to aspects of litigation in the Federal District Court, U.S. Court of Federal Claims, and U.S. Tax Court.
  • LAW TX 908: VAT and Other Consumption Taxes
    This course considers global consumption tax regimes, with a significant focus on Value Added Taxation (VAT) in the European Union. The course will not be limited to the EU VAT system, as important variations outside the EU will also be considered. The Canadian and New Zealand GSTs as well as the Israeli and Brazilian VATs will provide important contrasts. The Japanese consumption tax, an annual non-invoice VAT will also be considered. This course is not offered in 2012-2013
  • LAW TX 909: Pens & Def Comp
  • LAW TX 912: Independent Study
    An Independent Study Project provides an opportunity to earn one or two credits by completing an intensive research and writing project under close faculty supervision. Please contact the Graduate Tax Program office if you are interested in learning more about the requirements of an independent study.
  • LAW TX 913: Tax Accounting
    Examination of a broad range of subjects related to accounting methods and periods. Topics include principles of income recognition, prepaid income, claim of right, cash equivalency, and constructive receipt, special methods involving long-term contracts, depreciation, timing of deductions, estimated expenses, prepaid expense, expense versus capitalization, and conformity between tax and financial accounting.
  • LAW TX 914: Standards and Responsibilities in Tax Practice
    This course will consider the statutory, regulatory, and ethical standards and requirements applicable to tax practice and the tax lawyer's particular responsibilities in tax planning, preparation and advocacy. Students will be provided with an understanding of these requirements so that they may be recognized and applied in practice. There will be a focus on Circular 230, guidelines provided by the American Bar Association and tax return preparer rules.
  • LAW TX 915: Tx Exmpt Health
    This course description is currently under construction.
  • LAW TX 917: Taxation of Financial Products: Policy and Theory
    This course explores the financial characteristics and income taxation of financial instruments, with an emphasis on both policy and theory. We start with the building blocks of debt and equity, move on to the "derivatives" level of options and notional principal contracts (swaps), and conclude with exotica such as currency products. In each instance we will first look at the financial characteristics of the security (after the fashion of an MBA offering in corporate finance), and then study the tax rules governing each class of instrument. Because discounting (net present value) and "pay off" diagrams are so central to an understanding of financial instruments, the course incorporates a rigorous study of these mathematical tools. Also, when studying the tax rules applicable to financial products, we focus on the fundamental building blocks of taxation -- amount, timing, character, and source -- to reveal underlying policy and theory tensions that go to the very root of our income taxation system. The course is intended to complement TX 949 Taxation of Financial Products: Principles and Application, and may be taken either prior or subsequent to that class or on a stand alone basis. Pre or Co-requisite: Federal Income Taxation I and II.
  • LAW TX 920: Tax Aspects of Buying and Selling a Business
    A comprehensive course on how business owners can buy and sell businesses with a minimum tax cost and maximum after-tax return. The strategies for selling a business are often implemented from the moment the business entity is originally formed. The course will examine the crucial strategies, from choice of entity, to conducting ongoing operations, to the correct way to change or restructure existing C corporations, S corporations and other entities. The course will also examine the best way to structure a sale of a particular business, based on both the form of legal entity and on the specific facts in a case. For example, the course will compare a sale of stock to a sale of assets; will compare a sale for cash to a tax free transaction or part-cash, part-stock transaction; and compare the differences between a sale with immediate payment versus a possible installment sale. Prerequisites: Federal Income Taxation I and Federal Income Taxation II.
  • LAW TX 921: RICs, REITs,and REMICs
    An overview of the federal income taxation of passthrough entities such as REITs, RICs, and REMICs. The taxation of partnerships and S corporations will also be examined to establish points of comparison. Topics include the integration of the federal corporate and individual income tax, and the various methods through which integration can be achieved. Prerequisites: Introduction to Corporate Tax and Partnership Tax I. Notes: Limited enrollment. Final paper.
  • LAW TX 922: Tax Policy (Seminar)
    This seminar will examine criteria used to make administrative and legislative choices in taxation: equity, efficiency, administrability and simplicity. As a particular focus, we will study some of the connections between a tax system and spending programs. (Offered less than annually) Prerequisite: Federal Income Taxation I.
  • LAW TX 924: Corporate Reorganizations
    Income tax considerations relating to corporate tax free reorganizations including: review of the requirements for tax free treatment of acquisitive and time permitting divisive reorganizations; review of the tax treatment to all relevant parties to the transaction; consideration of special problems associated with certain types of reorganizations. Prerequisite: Introduction to Corporate Tax. Note: Limited enrollment.
  • LAW TX 925: Executive Compensation
    Study of the tax and ERISA aspects of various forms of executive compensation. Topics include traditional fringe benefits and deferred compensation arrangements, incentive and non-qualified stock option and restricted stock plans, stock appreciation rights, excess benefit arrangements, rabbi trusts, golden parachute agreements, split-dollar insurance arrangements, and special issues for tax-exempt organizations.
  • LAW TX 926: Exempt Organizations
    This course examines the formation, organization, operation and tax aspects of tax-exempt entities including charitable organizations, private foundations and various other tax-exempt entities such as healthcare organizations, social clubs, business leagues, trade associations, fraternal organizations and arts organizations. The course will analyze the following topics: the rationale for federal tax-exempt status; general considerations in organizing tax-exempt entities, including selection of appropriate form and methods of obtaining and maintaining tax-exempt status; distinctions between non-profit and tax exempt status; income taxation of exempt organizations; structuring relationships with nonprofit affiliates and for profit business organizations; liability and responsibility of agents, officers and directors; prohibited transactions; the taxation of unrelated business taxable income; private benefit/private inurement; intermediate sanctions; fundraising; political activities; and considerations in acquisitions, mergers and liquidations of exempt organizations. Pre or Co-Requisite: Federal Income Tax I
  • LAW TX 927: International Tax III- Advanced International Tax Issues (Seminar)
    This course will be of interest to those students who have decided that they likely will practice in the field of international taxation or who have a strong intellectual interest in this subject matter. The course will address in considerable detail a number of advanced and highly technical subjects, including: international acquisitions; review of rules applicable to reorganizations and particularly the application of section 367(a); the use of section 338 in international transactions; an overview of transfer pricing rules in regulations under section 482, with emphasis on pricing for services and intangibles; international tax issues associated with intangibles, including ownership of IP, licensing arrangements, qualified cost-sharing arrangements, and section 367(d); advanced use of hybrid entities in international structures; section 304 and its implication in international transactions; and section 367(b), emphasizing the surprising rules that are designed to close the back door to avoiding taxation of foreign E&P for CFCs. Depending on time other subjects or significant regulatory developments may be addressed. Prerequisites: International Tax I and International Tax II. Notes: Limited Enrollment. Grade based on a written paper of approximately 25 pages on a topic related to the course as agreed with the professors. This course is not offered in 2012-2013.