Courses

• LAW TX 951: US Transfer Pricing
  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.
• LAW TX 952: EU VAT
  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.
• LAW TX 953: Inbound International Taxation
  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.
• LAW TX 955: Taxation of Intellectual Property
  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.
• LAW TX 958: International Estate Planning
  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
• LAW TX 959: Making Tax Law
  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. Prerequisite: Federal Income Taxation I
• LAW TX 960: Executive Compensation- Advanced
  In this course we will take an in-depth look at the major Code provisions applicable to executive compensation. We will spend considerable time analyzing the regulations and other guidance under Code Sections 409A, 457, 162 and 280G. We will also consider recent changes to executive compensation rules implemented through recent bailout legislation. This will be a discussion intense course. Students will be expected to carry on high level discussions based on real-world examples. Students should have completed the Introductory Executive Compensation course or demonstrate ability beyond a basic level of knowledge in this subject area.

Note that this information may change at any time.

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