The Concentration in International Taxation provides not only an attractive opportunity for students to complete a concentration in this highly-relevant and specialized area of law. All tax classes will be offered entirely online, with no residency component, and are offered jointly by the Executive LLM Program and the online Graduate Tax Program.
In order to complete the concentration, students must complete 10 or more credits in the online Graduate Tax Program consisting of:
Federal Income Taxation I: LAW TX 901
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.
FALL 2018: LAW TX 901 A1 , Sep 4th to Dec 4th 2018
FALL 2018: LAW TX 901 OL , Sep 4th to Dec 6th 2018
Federal Income Taxation II: LAW TX 902
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.
FALL 2018: LAW TX 902 A1 , Sep 5th to Dec 5th 2018
FALL 2018: LAW TX 902 OL , Sep 4th to Dec 6th 2018
SPRG 2019: LAW TX 902 A1 , Jan 14th to Apr 22nd 2019
SPRG 2019: LAW TX 902 OL , Jan 14th to Apr 24th 2019
Tax Aspects of International Business: LAW TX 906
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.
FALL 2018: LAW TX 906 A1 , Sep 10th to Dec 3rd 2018
FALL 2018: LAW TX 906 OL , Sep 4th to Dec 6th 2018
SPRG 2019: LAW TX 906 A1 , Jan 23rd to May 1st 2019
Corporate Reorganizations: LAW TX 924
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 2019: LAW TX 924 A1 , Jan 16th to Apr 24th 2019
SPRG 2019: LAW TX 924 OL , Jan 14th to Apr 24th 2019
Introduction to Corporate Tax: LAW TX 933
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 2018: LAW TX 933 A1 , Sep 4th to Dec 6th 2018
FALL 2018: LAW TX 933 OL , Sep 4th to Dec 6th 2018
SPRG 2019: LAW TX 933 A1 , Jan 15th to Apr 23rd 2019
SPRG 2019: LAW TX 933 OL , Jan 14th to Apr 24th 2019
US Transfer Pricing: LAW TX 951
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 2019: LAW TX 951 A1 , Jan 18th to Apr 19th 2019
SPRG 2019: LAW TX 951 OL , Jan 14th to Apr 24th 2019
Inbound International Taxation: LAW TX 953
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 2019: LAW TX 953 A1 , Jan 15th to Apr 23rd 2019
SPRG 2019: LAW TX 953 OL , Jan 14th to Apr 24th 2019
*Tax Aspects of International Business is a required course for Executive LLM students wishing to complete the Concentration in International Taxation.
**Note: Federal Income Tax I & II are prerequisite or co-requisite for Corporate Tax and International Tax. Requirements and prerequisites can be waived based on prior coursework.
Students enrolled in the Executive LLM may enroll in any online Graduate Tax courses, subject to all requirements, prerequisites and co-requisites. However, only Federal Tax (if taken as a necessary prerequisite or co-requisite, as per the above), Corporate Tax, International Tax, and Transfer Pricing will be counted towards Executive LLM degree requirements.
For more information on the online Graduate Tax Program, please visit the online Graduate Tax Program web site.