Tax Law Courses

Tax law addresses the constitutional, common law, statutory, regulatory, and treaty provisions surrounding taxation of individuals, corporations, and other legal entities. Please note that some courses are not offered every year.

Foundational Courses

4 credits

The income tax is a pervasive feature of life in the United States and lawyers encounter tax issues in virtually every field of practice. This course introduces students to the fundamental principles of the federal income tax, and its impact on a wide range of matters, including employment, tort claims, divorce, retirement, and especially business activities and investments of all types. Topics include: the concept of income, determination of gross income, allowance of deductions and the determination of taxable income, identification of the taxpayer, taxable periods and timing, the determination of gain or loss (including realization and recognition) from dealings in property, the concept of income tax basis, and the process of change in the tax law. GRADING NOTICE: This course does not offer the CR/NC/H option.

FALL 2017: LAW JD 889 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Mon,Wed 10:40 am 12:40 pm 4 Alan L. Feld LAW 103
FALL 2017: LAW JD 889 W1 , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Tue,Thu 9:00 am 10:30 am 4 David I. Walker LAW 103
Fri 9:00 am 10:20 am 4 David I. Walker LAW 103
SPRG 2018: LAW JD 889 S1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue,Thu 9:00 am 10:30 am 4 Theodore S. Sims
Fri 9:00 am 10:20 am 4 Theodore S. Sims

2 credits

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.

FALL 2017: LAW TX 928 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Wed 6:30 pm 8:30 pm 2 Matthew D. Schnall LAW 101
FALL 2017: LAW TX 928 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Schnall

Corporate & Business Tax Courses

2 credits

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.

SPRG 2018: LAW TX 932 A1 , Jan 22nd to Apr 23rd 2018
Days Start End Credits Instructors Bldg Room
Thu 6:30 pm 8:30 pm 2 Wayne E. Smith
SPRG 2018: LAW TX 932 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Smith

2 credits

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.

SPRG 2018: LAW TX 924 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Thu 4:20 pm 6:20 pm 2 Wayne E. Smith
SPRG 2018: LAW TX 924 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Smith

2 credits

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.

FALL 2017: LAW TX 905 A1 , Sep 5th to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Russell A. Gaudreau LAW 101
FALL 2017: LAW TX 905 OL , Sep 1st to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Gaudreau

2 credits

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

FALL 2017: LAW TX 933 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Wed 4:20 pm 6:20 pm 2 Wayne E. SmithWayne E. Smith LAW 101
FALL 2017: LAW TX 933 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Smith
SPRG 2018: LAW TX 933 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Douglas S. Stransky
SPRG 2018: LAW TX 933 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Stransky

2 credits

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.

SPRG 2018: LAW TX 918 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Charles A. Wry
SPRG 2018: LAW TX 918 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Charles A. Wry

2 credits

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

FALL 2017: LAW TX 930 A1 , Sep 5th to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 David H. HalpertTravis L.L. Blais LAW 212
FALL 2017: LAW TX 930 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 HalpertBlais
SPRG 2018: LAW TX 930 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Mon 4:20 pm 6:20 pm 2 Robert M. Finkel
SPRG 2018: LAW TX 930 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Robert M. Finkel

2 credits

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.

SPRG 2018: LAW TX 940 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Patricia J. Jabar
SPRG 2018: LAW TX 940 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Jabar

2 credits

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.

Online section not open to JD students.

2 credits

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.

SPRG 2018: LAW TX 920 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Thu 4:20 pm 6:20 pm 2 Joseph B. Darby
SPRG 2018: LAW TX 920 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Joseph B. Darby

3 credits

Federal income tax considerations have major implications for planning in the corporate area. This course focuses on income tax issues in transactions between corporations and shareholders, including distributions, exchanges, reorganizations and capital contributions. PREREQUISITE: Introduction to Federal Income Taxation. GRADING NOTICE: This course does not offer the CR/NC/H option.

SPRG 2018: LAW JD 887 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue,Thu 10:45 am 12:15 pm 3 Alan L. Feld

General Courses

3 credits

This seminar will focus on the unique legal status of charitable organizations. Particular attention will be given to the expansion of charitable institutions from relief of poor people to different types of non-profit entities (including universities, hospitals, and religious organizations). We will examine their organization, governance, and regulation by both the federal government and the states. Specific topics will include the permissible scope of non-profit activities; choice of organizational form; the powers and fiduciary duties of non-profit directors/trustees and officers; standing to sue non-profits; qualification for federal tax-exempt status and related tax issues; forms of charitable giving and the regulation of fundraising; the investment and use of charitable funds; and other issues unique to non-profits. All students will be required to write papers on topics approved by the instructor. Some students, with the permission of the instructor, may satisfy the Upper-class Writing Requirement through this seminar by writing a longer paper. ENROLLMENT LIMIT: 18 students. GRADING NOTICE: This class will not offer the CR/NC/H option. OFFERING PATTERN: This class not offered every year. Students are advised to take this into account when planning their long-term schedule. ** A student who fails to attend the initial meeting of a seminar, or to obtain permission to be absent from either the instructor or the Registrar, will be administratively dropped from the seminar. Students who wait list for a seminar are required to attend the first seminar meeting to be considered for enrollment.

2 credits

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.

FALL 2017: LAW TX 913 A1 , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Christina RicePhillip G. Roshak LAW 413
FALL 2017: LAW TX 913 OL , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 RiceRoshak

1 credits

Tax law research is among the most complicated areas of the law to research. Statutes, regulations and agency issuances interact to create a thickly layered set of legal precedents. This class will explore the resources a tax professional would use to perform his or her research from legislative history to private letter rulings. Students will become familiar with the research platforms outside of Lexis and Westlaw that are commonly used in practice. Students will get practice in using many of the most heavily used practice materials. Classes will combine instruction and hands-on exercises using the major print and electronic resources available for tax law research. Students will be required to complete an assignment for each class. NOTE: This seminar satisfies the upper-class professional skills requirement. NOTE: Students may not add this course after the first class has been held. This course meets October 26 through December 7, 2016.

3 credits

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. PREREQUISITE: Introduction to Federal Income Taxation. LIMITED WRITING OPTION: A limited number of students will be able to satisfy the writing requirement with a paper. ** A student who fails to attend the initial meeting of a seminar, or to obtain permission to be absent from either the instructor or the Registrar, will be administratively dropped from the seminar. Students who waitlist for a seminar are required to attend the first seminar meeting to be considered for enrollment.

2 credits

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.

FALL 2017: LAW TX 907 A1 , Sep 7th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Thu 6:30 pm 8:30 pm 2 Sean McMahon LAW 101
FALL 2017: LAW TX 907 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 McMahon
SPRG 2018: LAW TX 907 A1 , Jan 22nd to Apr 23rd 2018
Days Start End Credits Instructors Bldg Room
Wed 4:20 pm 6:20 pm 2 Mark J. DeFrancisco
SPRG 2018: LAW TX 907 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Mark J. DeFrancisco

2 credits

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.

SPRG 2018: LAW TX 936 A1 , Jan 24th to May 2nd 2018
Days Start End Credits Instructors Bldg Room
Wed 4:20 pm 6:20 pm 2 Staff
SPRG 2018: LAW TX 936 OL , Jan 18th to May 2nd 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Staff

2 credits

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.

Online section not open to JD students.

SPRG 2018: LAW TX 917 A1 , Jan 22nd to Apr 23rd 2018
Days Start End Credits Instructors Bldg Room
Mon 6:30 pm 8:30 pm 2 Ameek A. Ponda
SPRG 2018: LAW TX 917 OL , Jan 16th to May 1st 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Ameek A. Ponda

2 credits

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. Prerequisite or corequisite: Federal Income Taxation I and II

Online section not open to JD students.

2 credits

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.

FALL 2017: LAW TX 955 A1 , Sep 7th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Thu 4:20 pm 6:20 pm 2 Joseph B. Darby LAW 101
FALL 2017: LAW TX 955 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Darby

Individual Tax Courses

2 credits

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.

FALL 2017: LAW TX 905 A1 , Sep 5th to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Russell A. Gaudreau LAW 101
FALL 2017: LAW TX 905 OL , Sep 1st to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Gaudreau

2 credits

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.

FALL 2017: LAW TX 904 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Mon 4:20 pm 6:20 pm 2 Harry S. Miller LAW 413
FALL 2017: LAW TX 904 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Miller

2 credits

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

FALL 2017: LAW TX 935 A1 , Sep 5th to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Melissa LangaRuth Mattson LAW 209
FALL 2017: LAW TX 935 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 LangaMattson
SPRG 2018: LAW TX 935 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Anne Gibson

3 credits

This seminar will explore the theories and skills involved in the estate planning and administration process. Initial class discussions will focus on selected non-tax topics in estates, trusts, and fiduciary law, including asset protection, duties of loyalty and care, accountability to beneficiaries, and dynasty trusts. During the semester, each student will choose a research topic, give an oral presentation, and complete a substantial paper reflecting the results of the research. ** A student who fails to attend the initial meeting of a seminar, or to obtain permission to be absent from either the instructor or the Registrar, will be administratively dropped from the seminar. Students who waitlist for a seminar are required to attend the first seminar meeting to be considered for enrollment.

2 credits

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

SPRG 2018: LAW TX 934 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Thomas E. Peckham
SPRG 2018: LAW TX 934 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Peckham

2 credits

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. None. Recommended: Federal Income Taxation I, Federal Income Taxation II and Estate and Gift Taxation.

SPRG 2018: LAW TX 950 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Jeremiah W. Doyle
SPRG 2018: LAW TX 950 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Doyle

3 credits

Federal income tax considerations have major implications for planning in the corporate area. This course focuses on income tax issues in transactions between corporations and shareholders, including distributions, exchanges, reorganizations and capital contributions. PREREQUISITE: Introduction to Federal Income Taxation. GRADING NOTICE: This course does not offer the CR/NC/H option.

SPRG 2018: LAW JD 887 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue,Thu 10:45 am 12:15 pm 3 Alan L. Feld

2 credits

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.

SPRG 2018: LAW TX 937 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Thu 4:20 pm 6:20 pm 2 Leo J. Cushing
SPRG 2018: LAW TX 937 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Cushing

International Tax Courses

2 credits

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. There are no pre-requisites for this course.

FALL 2017: LAW TX 952 A1 , Sep 8th to Dec 8th 2017
Days Start End Credits Instructors Bldg Room
Fri 1:15 pm 3:15 pm 2 Ainsworth LAW 101
FALL 2017: LAW TX 952 OL , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Ainsworth

2 credits

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. Prerequisite or corequisite: Federal Income Taxation I; Recommended: Tax Aspects of International Business

SPRG 2018: LAW TX 953 A1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Douglas S. Stransky
SPRG 2018: LAW TX 953 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Stransky

2 credits

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

SPRG 2018: LAW TX 958 A1 , Jan 17th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
Wed 6:30 pm 8:30 pm 2 Harry S. Miller
SPRG 2018: LAW TX 958 OL , Jan 15th to Jan 26th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Harry S. Miller

2 credits

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. Pre or co-requisite: Tax Aspects of International Business.

FALL 2017: LAW TX 939 A1 , Sep 7th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Thu 4:20 pm 6:20 pm 2 Brainard L. Patton LAW 209
FALL 2017: LAW TX 939 OL , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Brainard L. Patton

2 credits

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.

SPRG 2018: LAW TX 951 A1 , Jan 17th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
Fri 11:00 am 1:00 pm 2 Richard T. Ainsworth
SPRG 2018: LAW TX 951 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Ainsworth

Related Courses

4 credits

Marks, Tung and Walker: Course about the legal structure and characteristics of business corporations. Topics include the promotion and formation of corporations; the distribution of power between management and shareholders; the limitations on management powers imposed by state law fiduciary duties and federal securities laws; shareholder derivative suits; capital structure and financing of corporations; and fundamental changes in corporate structure, such as mergers and sales of assets. The course serves as a prerequisite to advanced courses. PREREQUISITE: Business Fundamentals. GRADING NOTICE: The CR/NC/H option is only offered in Professor Marks's section. Ellias: This course is an introduction to the basic legal rules and principles governing corporations. We examine three basic problems: (1) conflicts between a firm's managers and its owners (the shareholders); (2) conflicts between shareholders; and (3) conflicts between shareholders and creditors. We examine the costs associated with these conflicts and how markets, legal rules, and contracts might reduce them. This is a foundational law school course that provides the fundamental knowledge of business and finance needed for upper level classes. No prior knowledge of business or finance is expected. PREREQUISITE: Business Fundamentals. GRADING NOTICE: This class does not offer the CR/NC/H option.

FALL 2017: LAW JD 816 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Mon,Wed 2:10 pm 4:10 pm 4 Frederick Tung LAW 414
FALL 2017: LAW JD 816 M1 , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Tue,Thu 2:10 pm 4:10 pm 4 Stephen G. Marks LAW 103
SPRG 2018: LAW JD 816 E1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue,Thu 8:30 am 10:30 am 4 Staff
SPRG 2018: LAW JD 816 W1 , Jan 17th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
Mon,Wed 10:40 am 12:40 pm 4 David I. Walker

2 credits

The course will offer a careful introduction to some of the tools used in the analysis of problems encountered in the social sciences, principally economics and finance, but also in fields as diverse as political science, sociology, and public health. The topics principally covered will consist of discounting (that is, the computation of present and future values); an elementary introduction to probability and statistics, sufficient to acquaint the student with the determination and significance of the expected value, variance, and standard deviation of a discrete probability distribution or the outcomes of an experiment; and some of the principal tools used to analyze decisions made under conditions of uncertainty, including statistical decision theory and expected utility (in connection with which the course will include a formal introduction to "risk tolerance", and what it means to be risk-loving, risk-neutral, or risk-averse). The course will include applications of these tools to the study of legal issues.

SPRG 2018: LAW JD 997 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Thu 2:10 pm 4:10 pm 2 Theodore S. Sims

2 credits

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.

4 credits

Professor Seipp's Section: This course explores the basic law surrounding the disposition of property at death: (1) overview of the estate planning process and the policy considerations regarding inheritance law; (2) the process by which property is distributed in the absence of a will (intestacy); (3) the law of wills, examining formal requirements for the execution of a valid will, revocation, challenges to a will, and construction; (4) will substitutes and planning for incapacity; (5) the law of trusts, including revocable and pour-over trusts, creditor and beneficiary rights, and spendthrift trusts; (6) powers of appointment, perpetuities, and brief coverage of charitable trusts. This course does not address in detail tax-motivated estate planning. Professor Hurwitz's Section: This course explores the basic law surrounding the disposition of property at death: (1) overview of the estate planning process and the policy considerations regarding inheritance law; (2) the process by which property is distributed in the absence of a will (intestacy); (3) the law of wills, examining challenges to a will, formal requirements for the execution of a valid will, revocation, and construction; (4) will substitutes and planning for incapacity; (5) the law of trusts, including revocable and pour-over trusts, and creditor and beneficiary rights; (6) brief coverage of powers of appointment, perpetuities, spendthrift, and charitable trusts. This course does not address in detail tax-motivated estate planning.

FALL 2017: LAW JD 871 A1 , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Tue,Thu 8:30 am 10:30 am 4 Ilana Hurwitz LAW 605
SPRG 2018: LAW JD 871 S1 , Jan 16th to Apr 24th 2018
Days Start End Credits Instructors Bldg Room
Tue,Thu 10:40 am 12:40 pm 4 David J. Seipp