Course Schedules

 

Course Descriptions and Prerequisites

2 credits

This course considers different solutions adopted by nine industrialized countries (Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom, and the United States) to common problems in income tax design. It responds to the need for a broader understanding of the way that tax matters are handled in different countries as business transactions become increasingly global. The course presents a policy-focused overview of variant tax treatments in individual, business (corporate and partnership) and cross-border transactions. The intent is not to develop an expertise in any one, or any group of tax systems, but rather to provide a comparative knowledge base upon which a further, in-depth inquiry can be based.

Online section not open to JD students.

FALL 2017: LAW TX 957 A1 , Sep 8th to Dec 1st 2017
Days Start End Credits Instructors Bldg Room
Fri 11:00 am 1:00 pm 2 Richard T. Ainsworth LAW 101
FALL 2017: LAW TX 957 OL , Sep 8th to Dec 1st 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Ainsworth

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

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

This Course will cover the legal, evidentiary, and procedural challenges presented in the prosecution of criminal tax cases. Class discussion will cover basic criminal tax violations found in United States Code Title 26 and a selection of federal crimes found in Title 18. The Course will also cover: IRS and Department of Justice, Tax Division practice and procedure; IRS audit, appeal and collection procedure and parallel civil and criminal tax procedures; the various methods of proof used by the IRS in investigating and prosecuting criminal tax fraud cases; federal grand jury practice; financial records search warrants; federal conspiracy and money laundering offenses; testimonial and document production immunity; foreign evidence processes, including select portions of the Title III of the USA PATRIOT ACT (also known as the International Money Laundering and Anti-Terrorist Financing Act of 2001; and application of criminal tax offenses to terrorism financing cases.

FALL 2017: LAW TX 981 OL , Sep 4th to Dec 8th 2017
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

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

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

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

FALL 2017: LAW TX 926 A1 , Sep 11th to Dec 4th 2017
Days Start End Credits Instructors Bldg Room
Mon 6:30 pm 8:30 pm 2 Jeremiah W. Doyle LAW 209
FALL 2017: LAW TX 926 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Doyle

2 credits

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 2017: LAW TX 901 A1 , Sep 5th to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
Tue 6:30 pm 8:30 pm 2 Charles W. Maurer LAW 101
FALL 2017: LAW TX 901 OL , Sep 1st to Dec 5th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Maurer
SPRG 2018: LAW TX 901 A1 , Jan 18th to Apr 19th 2018
Days Start End Credits Instructors Bldg Room
Thu 6:30 pm 8:30 pm 2 Paul Colleran
SPRG 2018: LAW TX 901 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Paul Colleran

2 credits

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 2017: LAW TX 902 A1 , Sep 6th to Dec 6th 2017
Days Start End Credits Instructors Bldg Room
Wed 6:30 pm 8:30 pm 2 Charles A. Wry LAW 212
FALL 2017: LAW TX 902 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Wry
SPRG 2018: LAW TX 902 A1 , Jan 22nd to Apr 23rd 2018
Days Start End Credits Instructors Bldg Room
Mon 6:30 pm 8:30 pm 2 Thomas Hammond
SPRG 2018: LAW TX 902 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Thomas Hammond

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

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

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: None

SPRG 2018: LAW TX 959 A1 , Jan 22nd to Apr 30th 2018
Days Start End Credits Instructors Bldg Room
Mon 4:20 pm 6:20 pm 2 Staff
SPRG 2018: LAW TX 959 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Berman

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

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

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

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.

2 credits

TX978 is an introductory course in the reporting of income taxes on financial statements under US Generally Accepted Accounting Principles (US GAAP). This course covers financial reporting rules that every tax attorney needs to know to be conversant with business clients and other tax professionals. Subjects include deferred taxes, valuation allowance, uncertain tax positions, effective tax rate, and permanent reinvestment of subsidiary earnings.

SPRG 2018: LAW TX 978 A1 , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
Wed 6:30 pm 8:30 pm 2 Phillip G. RoshakChristina Rice
SPRG 2018: LAW TX 978 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Roshak

2 credits

This course examines the convergence of technology solutions, in support of taxation, from two different angles: corporations and government. The course will also compare and contrast these movements in America with other countries, as US-headquartered companies expanding abroad face new realities, unfamiliar tax structures and increasingly complex regulatory environments; and legal and tax professionals must be prepared for these challenges. Rather than focus on technology per se, analyzing computer programming language and codes, the bias of this course is the real-life business perspective of technology when applied to taxation and fiscal policy. This course gives students exclusive access to tax software actually used by multinational corporations to determine indirect taxes in the US and nearly 200 other countries and foreign tax jurisdictions. This access will allow students to simulate domestic/international transactions and analyze their tax implications while becoming familiar with the mechanics of an Enterprise-class tax automation solution.

FALL 2017: LAW TX 968 A1 , Sep 11th to Dec 4th 2017
Days Start End Credits Instructors Bldg Room
Mon 6:30 pm 8:30 pm 2 Camilo Martinez LAW 101
FALL 2017: LAW TX 968 OL , Sep 1st to Dec 4th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Martinez

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

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

2 credits

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 2017: LAW TX 906 A1 , Sep 11th to Dec 4th 2017
Days Start End Credits Instructors Bldg Room
Mon 4:20 pm 6:20 pm 2 William W. Park LAW 605
FALL 2017: LAW TX 906 OL , Sep 5th to Dec 11th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Park

2 credits

The principal objective of this course is to study the fundamental federal tax provisions governing the dissolution of a marriage. The course will cover the common tax issues arising as the result of a marital dissolution including alimony, child support, property settlements, filing status, deductible of expenses, allocation of tax carryforwards, liability for tax deficiencies and estate and gift tax issues. The course will concentrate on the tax rules relating to alimony and property settlement. To the extent time is available at the end of the course, we will discuss the exposure of trust assets to creditor's (ex-spouse's) claims. Recommended: Federal Income Tax I

FALL 2017: LAW TX 980 A1 , Sep 11th to Dec 4th 2017
Days Start End Credits Instructors Bldg Room
Mon 4:20 pm 6:20 pm 2 Jeremiah W. Doyle LAW 209
FALL 2017: LAW TX 980 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Doyle

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

2 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.

FALL 2017: LAW TX 985 OL , Sep 5th to Dec 18th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 TBA

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

This course provides an opportunity for students to conduct in-depth research and to improve their writing skills on current issues in taxation. This class meets weekly to discuss tax law developments globally at the State & Local, US Federal and International topics and to review the topic proposal and outlines of class participants.

SPRG 2018: LAW TX 982 A1 , Jan 19th to Apr 20th 2018
Days Start End Credits Instructors Bldg Room
Fri 1:15 pm 3:15 pm 2 Richard T. Ainsworth
SPRG 2018: LAW TX 982 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Ainsworth

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

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

2 credits

This course undertakes a detailed examination of Federal Income Taxation of S Corporations using a contextual approach so that students will be able to identify opportunities and pitfalls in the use of S Corporations. This will be accomplished through a combination of reading the Internal Revenue Code, regulations and other authorities relating to Federal Income Taxation of S Corporations. Use of S corporations in a multinational setting will also be considered. The course will emphasize, teach, expect, and measure the internalization of professional responsibilities in tax practice to clients using actual judicial decisions as well as hypothetical case studies. The inherit tension resulting from duties to clients and duties to the tax system is explored. We will also explore the various settings in which choice of entity for business operations will be a consideration and the utility of such choices for tax and non-tax purposes. Students will practice analytical and writing skills through written assignments. Since a contextual approach is used, it is expected that students will acquire knowledge of substantive tax law in addition to an understanding of ethical and legal responsibilities in federal tax practice.

FALL 2017: LAW TX 984 A1 , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
Wed 6:30 pm 8:30 pm 2 David B. CastenTBA LAW 209
FALL 2017: LAW TX 984 OL , Sep 5th to Dec 7th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 CastenTBA

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

2 credits

This course will focus on the practice techniques and tools to provide a foundation in transfer pricing economic analysis and preparation of transfer pricing studies. Students will have the opportunity to experience applying the concepts of Section 482 in everyday business situations. The objective will be to bring legal, economics and financial disciplines together. Through case studies and small group projects, we will examine core concepts of transfer pricing practice: actual application of transfer pricing methods (CPM, CUT, profit split and IP valuation techniques). We will also connect these techniques to implementation in current events such as BEPS action items 7, 8, 9, 10 and 13. We will use real case studies in an effort to ready students for actual transfer pricing practice.

SPRG 2018: LAW TX 979 A1 , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
Mon 6:30 pm 8:30 pm 2 Candice KingAndrew Shact
SPRG 2018: LAW TX 979 OL , Jan 16th to Apr 25th 2018
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Andrew Shact

2 credits

Understanding the policy drivers that underlie the formation of tax rules is a valuable asset for a tax advisor. Knowledge of the technical rules can become dated as laws and regulations change, but a sophistication about the policy drivers will remain relevant throughout a tax career. This course will help a student to develop instincts about how the rules are most likely to work, and to evolve. In most cases, there are limited policy design choices available to legislators, and an observer can see repeating patterns in history and across various countries. This course, with an emphasis on debate and discussion, will provide an overview of the policy objectives and the political drivers that commonly shape the formation of tax laws. There are no prerequisites for this course.

FALL 2017: LAW TX 987 A1 , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
Tue 4:20 pm 6:20 pm 2 Staff LAW 209
FALL 2017: LAW TX 987 OL , Sep 5th to Dec 12th 2017
Days Start End Credits Instructors Bldg Room
ARR TBD TBD 2 Staff

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