Courses

• LAW TX 928: State and Local Taxation
  The basic workings of the major state and local taxes, including personal income taxes, sales and use taxes, property taxes, and corporate taxes. Topics include issues arising from the multi-jurisdictional nature of the state and local tax apparatus, the principle aspects of federal statutory and constitutional law affecting state taxation, the application of basic tax concepts to current issues facing state tax administrators and practitioners, including tax advantages business structures, and some of the legislative responses to such issues. Prerequisite: Federal Income Taxation I.
• LAW TX 929: Tax Planning (Seminar)
  Methods and techniques of analyzing tax problems and preparing plans to carry out individual and corporate transactions by means advantageous from a tax point of view. The seminar considers application of all branches of federal and state tax law in the preparation of such plans. Students are required to prepare for participation in discussion of a variety of problems. Prerequisites: Federal Income Taxation I, Federal Income Taxation II, Introduction to Corporate Tax, and Introduction to Partnership Tax. Notes: Limited enrollment. Final paper in lieu of exam. (Offered less than anually)
• LAW TX 930: Partnership Tax I
  Presents an overview of subchapter K and the federal income tax treatment of partnerships and other entities, such as limited liability companies;. Topics include tax classification of a partnership versus a corporation or trust; considerations in choice of entity;basic partnership accounting and capital accounts, partnership formation and acquisition of partnership interests for property or services; determination of basis;basic rules allocations of income and loss ; taxation of normal partnership operations; distributions of cash and property; transactions between partners and partnership, including sales of partnership interests. Co- and prerequisites: Federal Income Tax I and Federal Income Tax II.
• LAW TX 931: Tax Controversies (Seminar)
  This seminar examines federal tax controversy practice, concentrating on litigation of deficiency actions in the United States Tax Court. Discussion includes administrative law issues, court procedures and pleadings, alternative dispute resolution, trial strategies, and ethical considerations. Student papers and presentations defend proposals to improve current practice. Prerequisite: Tax Practice and Procedure. Notes: Limited enrollment. Paper and oral presentation in lieu of final exam. (Offered less than anually)
• LAW TX 932: Consolidated Corporations
  Survey of the U.S. income taxation of corporations filing consolidated tax returns. Provides a general understanding of the consolidated return regulations and enables students to identify tax issues involving corporations filing or wishing to file consolidated returns. The application of the consolidated return regulations to complex business transactions is considered. Prerequisites or corequisites: Federal Income taxation I, Federal Income Taxation II, and Introduction to Corporate Tax, or equivalent experience.
• LAW TX 933: Introduction to Corporate Tax
  Income tax considerations relating to transfers of assets and liabilities to a corporation (during incorporation and otherwise), non-liquidating distributions, stock redemptions, related party stock purchases and corporate liquidations. Includes an overview of the treatment of a corporate shareholder versus other shareholders. Prerequisites or corequisites: Federal Income Taxation I and Federal Income Taxation II. Co- and prerequisites: Federal Income Tax I and Federal Income Tax II.
• LAW TX 934: Estate Planning- Advanced
  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 GRATS, QPRTs, sales of property to “intentionally defective grantor trusts,” as well as marital and charitable deduction issues, post-mortem planning and planning for retirement. Pre-requisites: Estate Planning, Estate and Gift Taxation Co-requisites: Taxation of Trusts and Fiduciaries
• LAW TX 935: Estate Planning
  This course will examine in depth the theoretical and practical aspects of a variety of estate planning strategies currently being used in the real world. The primary focus of the course will be on federal income, estate, gift, and generation skipping transfer tax issues which arise in the estate planning context, although other planning issues, including professional ethics, will also be considered. The course will use case studies of specific tax driven planning strategies, including grantor trusts, marital deduction trusts, post-mortem planning, and planning for incapacity. Prerequisites or corequisites: Federal Income Taxation I and Estate and Gift Taxation.
• LAW TX 936: Taxation of Bankruptcies and Workouts
  Study of the tax and opportunities arising in bankruptcy and nonbankruptcy workouts of individuals, partnerships, and corporations. Topics include cancellation of indebtedness income from the reduction or renegotiation of debt, gain or loss recognition on foreclosures and similar property transfers, restrictions on net operating loss carryovers, special tax consequences of the restructuring of partnership debt and equity, the taxation of the bankruptcy estate and its owners and creditors, and trust fund tax penalties on officers, directors, and other individuals. Prerequisites or corequisites: Introduction to Corporate Tax and Introduction to Partnership Tax.
• LAW TX 937: Taxation of Trusts and Fiduciaries
  Income tax consequences arising upon the death of a decedent and special income tax treatments of estates, trusts, and fiduciaries. Topics include determination of gross income and allocation between the decedent and the estate or trust; special problems with income in respect of a decedent; separate and conduit taxation of estates and trusts; allocation of tax attributes between an estate or trust and its beneficiaries; grantor trust rules, and other topics. Prerequisite: Federal Income Taxation I.
• LAW TX 938: Tax Issues in Business Decisions
  Nearly every business decision has tax implications: compensation packages, M&A activity, R&D, movements of cash, changing or expanding lines of business, deciding the locations in which business activity should be carried out, whether to export, and so on. Even though business decisions drive tax results, there is often little understanding among decision-makers of the tax consequences of their decisions. From the other side, tax practitioners often propose tax-planning strategies without understanding the business complexities that may be involved in implementing those strategies. This course will offer students a practical approach to the management of tax expense as a business problem which requires input and involvement from every part of a business. Throughout the course, emphasis will be placed on the EPS and cash flow effects of tax expense, although the technical tax rules will also be applied. The overall approach of the course will be to use case studies to promote class discussion. Students will be evaluated based on class participation, and on a written assignment. The written assignment will be completed in teams of two to four, with at least one business school student, and one law school student.
• LAW TX 939: International Tax II- Outbound US Taxation, the Foreign Tax Credit and Subpart F
  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. Prerequisite or corequisite: International Tax I
• LAW TX 941: Property Transactions- Advanced
  Federal income tax aspects of property transactions that are more advanced than those covered by Federal Income Taxation II. Topics include 1.Debt financings (including debt vs. equity issues, debt modifications, transfers and reacquisitions of property in satisfaction of debt, and guarantees) 2.Options 3.Like-kind exchanges and involuntary conversions 4.Leasing transactions (including sale-leasebacks) 5.Tax shelters. Prerequisites: Federal Income Taxation I and Federal Income Taxation II. (Offered less than anually)
• LAW TX 942: Tax Exempt Financing
  Why state and local government entities borrow money and what they can and cannot do with the money. Exploration of the mysteries of eleven Code provisions any myriad regulations governing the simple act of municipal borrowing and probe the depths of the arcane rules relating to arbitrage. Topics include the private activity bond rules, housing bonds, exempt activity bonds, and small issue bonds. At the end of the course we will be able to understand why the classroom in which the course is taught is very likely to have been financed with a tax-exempt bond. (Offered less than anually)
• LAW TX 943: Taxation of Insurance Companies
  Insurance is a form of risk management. Historically, insurance companies have been subject to special accounting and regulatory treatment, which has led to special tax treatment. This in turn may influence the choice of insurance as a risk management tool and the manner in which the transaction is structured. This course is intended as an introduction to the taxation of insurance companies at the federal level for students with no previous background in insurance or the taxation of insurance companies. Students should have completed courses in basic income tax and the taxation of corporations. The course covers three broad topics: insurance transactions, accounting and regulation; the taxations of life insurance companies; and the taxation of property and casualty insurance companies. As time permits, specific issues may be examined in greater detail involving topics such as captive insurance companies, demutualization, Blue Cross and Blue Shield organizations, health insurance and finite reinsurance. (Offered less than anually)
• LAW TX 944: Structuring Intellectual Property Ownership
  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.
• LAW TX 945: Subchapter S Corporations
  The fundamentals of Subchapter S corporations. Topics include uses and eligibility of S corporations; basis of stock and debt; taxation of income, losses, deductions and credits; termination of Subchapter S status; distributions; built-in gains tax; passive investment issues; compensation; and S corporation reorganizations and divisions. (Offered less than anually)
• LAW TX 946: Real Estate Taxation
  An in depth examination of the federal income tax aspects of real estate transactions. Topics include acquisition issues, use of various forms of debt and equity financing, calculation of initial basis, allocation of purchase price and depreciation issues; disposition issues, including calculation of amount and character of gain or loss and installment sales rules, tax deferred transactions, including like-kind exchanges and involuntary conversions.
• LAW TX 949: Taxation of Financial Products: Principles and Application
  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. Pre or Co-requisites: Federal Income Taxation I & II.
• LAW TX 950: Tax Aspects of Charitable Giving
  Charitable gift planning has long been a crucial component in wealth management and estate planning. It remains an important factor in the “tool box” 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. Pre-requisites: Federal Income Tax I, Federal Income Tax II.

Note that this information may change at any time.

Back to full list of School of Law