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
    Undergraduate Prerequisites: TX 901
    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. Prerequisite or corequisite: Federal Income Taxation I.
  • 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 913: Tax Law of Accounting Methods
    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. Prerequisite or corequisite: Federal Income Taxation I.
  • 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 918: Life Cycle of a Business Venture
    The federal income tax laws significantly affect the way a business venture proceeds through the various stages of its life cycle. This course will explore the federal income tax aspects of: i) choosing the proper form of entity (typically, C corporation, S corporation or LLC) to carry on a business, ii) forming the entity that will carry on the business and issuing equity interests (and rights to acquire equity interests) in the entity to founders and other service providers, iii)financing the entity with debt and equity, iv) reporting the results of the entity's operations, v) purchasing and leasing assets, vi) buying out owners, vii) selling the business. Co- and prerequisites: Federal Income Taxation I, Federal Income Taxation II, Introduction to Corporate Tax and Partnership Tax I.
  • 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 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 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 928: State and Local Taxation
    The course will expose students to the basic workings of the major state and local taxes, including personal income taxes, sales and use taxes, property taxes, and corporate taxes. We will also explore the special issues arising from the multi-jurisdictional nature of the state and local tax apparatus, and the principal aspects of federal statutory and constitutional law affecting state taxation. We will consider the application of basic state tax concepts to current issues facing state tax administrators and practitioners, including tax advantaged business structures, and some of the legislative responses to such issues. Prerequisite or corequisite: Federal Income Taxation I.
  • LAW TX 930: Partnership Tax I
    Presents an overview of subchapter K and the federal income tax treatment of partnerships and other entities, such as limited liability companies;. Topics include tax classification of a partnership versus a corporation or trust; considerations in choice of entity;basic partnership accounting and capital accounts, partnership formation and acquisition of partnership interests for property or services; determination of basis;basic rules allocations of income and loss ; taxation of normal partnership operations; distributions of cash and property; transactions between partners and partnership, including sales of partnership interests. Prerequisite or corequisite: Federal Income Taxation I and II, Introduction to Corporate Tax
  • LAW TX 932: Consolidated Corporations
    Survey of the U.S. income taxation of corporations filing consolidated tax returns. Provides a general understanding of the consolidated return regulations and enables students to identify tax issues involving corporations filing or wishing to file consolidated returns. The application of the consolidated return regulations to complex business transactions is considered. Prerequisites: Federal Income Taxation I, Federal Income Taxation II, and Introduction to Corporate Tax, or equivalent experience.
  • 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. Prerequisite or corequisite: Federal Income Taxation I and II
  • LAW TX 934: Estate Planning- Advanced
    This course picks up the estate planning course (TX 935) leaves off. We will survey several "cutting edge" estate planning techniques-techniques that permit the transfer of large amounts of wealth at little or no gift tax or estate tax cost. We will zero in on valuation rules that apply to the estate tax and gift tax; we will discuss what to look for in appraisals; we will examine, in depth, the current status of planning involving family partnerships and LLCs; we will examine the rules that apply to GRATs, installment sales to "defective" grantor trusts, and how to structure transfers using these techniques; we will review the biases built into the actuarial valuation rules that the Internal Revenue Service requires us to apply; we will examine the effects of the UPC, the Uniform Trust Code, and will consider "decanting"; we will discuss some of the psychological aspects of estate planning including issues presented by parents' fears of making their children too wealthy too soon; and we will discuss trust design and the choice of trustees. There is no final exam but students will be required to write a 10 -- 15 page term paper. In addition there will be several quizzes throughout the semester. Prerequisite: Estate Planning and Estate and Gift Tax Recommended: Taxation of Trusts and Fiduciaries
  • 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. Prerequisite or corequisite: Federal Income Taxation I and Estate and Gift Tax
  • 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.