Academic, Course, and Registration Information

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

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. Course Structure: This course follows an assigned text. After the opening class the course is structured in three equal (four-class) segments on (1) Individual, (2) Business and (3) International tax topics. An effort will be made when appropriate to update the materials in the text, allowing us to discuss some current problems.

Online section not open to JD students.

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.

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.

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.

Understanding the differences between Medicare and Medicaid. Exploring the operation of a Durable Power of Attorney and a Health Care Proxy in connection with the admission of a loved one to a nursing home. A walk through the Federal and corresponding Massachusetts Medicaid Regulations as they relate to: understanding what is a countable and non countable asset for Medicaid eligibility purposes: exploring the five year look back period versus the period of ineligibility resulting from disqualifying transfers along with related exceptions to these rules; discuss real estate as a countable and non countable asset including the different treatment of a primary residence, vacation home and rental properties along with ways to convert these countable assets to non countable assets; last minute planning techniques with annuities and personal care contracts; understanding the drafting and operation of Medicaid Irrevocable Trusts including a complete analysis of the Income, Gift and Estate Tax consequences of using these trusts from Grantor Trust rules to step up in basis, use of life estates along with real life fact patterns that explain the planning opportunities and related pitfalls to be avoided.

This course provides an introduction to the regulation of retirement plans covered under the Employee Retirement Income Security Act of 1974 ("ERISA"), a federal law that transformed the legal landscape of private-sector retirement plans. Specifically, the course will cover public policy implications of offering and regulating retirement plans including tax policy concerning incentives for employers to offer retirement plans and for employees to defer income to these plans, the different types of retirement plans subject to regulation under ERISA with a focus on defined contribution plans such as cash or deferred arrangements (401(k) plans) under the Internal Revenue Code, how plans qualify for preferential tax treatment under the Code, federal preemption of ERISA-governed benefit plans, ERISA's fiduciary duties and prohibited transaction rules, and civil enforcement in the courts as well as by the Internal Revenue Service and the Department of Labor. The course will be relevant for any student interested in employee benefits, tax law, employment law, labor law, business law, or securities law.

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.

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

Study of the tax and ERISA aspects of various forms of executive compensation. Topics include traditional fringe benefits and deferred compensation arrangements, incentive and non-qualified stock option and restricted stock plans, stock appreciation rights, excess benefit arrangements, rabbi trusts, golden parachute agreements, split-dollar insurance arrangements, and special issues for tax-exempt organizations.

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

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.

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.

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

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

International information reporting and withholding are the future of tax work. They are a source of revenue for the IRS through penalties and a source of anxiety for many tax practitioners, especially with the expanded reporting requirements newly enacted as part of the TCJA. A strong grounding in international information compliance and withholding transactions can benefit every practitioner from the estate planner to the corporate tax advisor. This course will cover the reporting requirements for US taxpayers who hold non-US assets, and the withholding requirements when US payors make payments to non-US persons. Students will become familiar with the various forms associated with different assets, such as the Foreign Bank Account Report ("FBAR") which is used to report foreign assets. We will cover how and when to file, the basics of how to prepare the form, and the penalties for noncompliance. The course will comprehensively cover informational reporting forms to report all foreign assets including closely held business interests, foreign trusts, and the receipt of gifts from non-US persons. We will discuss how the Foreign Account Tax Compliance Act ("FATCA") created a worldwide network of information about non-US assets, and what individuals and fiduciaries need to know to remain compliant. Finally, in addition to covering the reporting associated with non-US ties, we will discuss withholding under Chapter 3 of the Internal Revenue Code and identify when and how to withhold US tax from payments to non-US entities and non-US persons.

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

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.

This course examines the current outbound international tax rules, but will demonstrate that the law in this area is more than a collection of those rules. It is instead a process, ever evolving, to address its various contexts and constituencies. We will examine the relevant contexts -- Constitutional, international (WTO, OECD) and commercial -- and will engage in class discussions applying the rules within those frameworks. The objective is for students to gain enough grounding in the rules to start a path toward mastery, and to understand the drivers behind the rules so that students can apply them as they exist today, and analyze changes as they occur in the future. Pre or co- requisite: Tax Aspects of International Business (recommended)

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

This 2.0 hour seminar will provide a basic overview of state and local tax, and consideration of each of the major taxes imposed by state and local governments, with an emphasis on the sales and use tax and the corporate income tax. The course will consider: (1) the policy considerations that underlie the various types of taxes and their collection; (2) the major restrictions that apply under the U.S. Constitution and federal law; (3) state law conformity with the provisions of the Internal Revenue Code; and (4) the relationship of the states to one another as taxing entities in the U.S. Constitutional system. The course will focus on state and local tax from both a taxpayer and government perspective, with a special emphasis on practical dilemmas. The scope of the course will be national, with a focus on current issues; however, examples will frequently be drawn from Massachusetts tax practice. Enrollment limited to students in State and Local Tax Externship program

The course will expose students to the major types of United States state and local taxes,including personal income taxes, sales and use taxes, property taxes, and corporate taxes.We will explore the structure of each of these types of taxes, how the taxes are implemented in various jurisdictions, and some of the significant issues that arise in applying the taxes. We will also cover some special issues arising from the multi- jurisdictional nature of state and local taxation, and the principal aspects of United States federal law, both statutory and constitutional, that shape and constrain state tax systems. 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.

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.

This course is designed to provide an introductory understanding of the theory and principles by which decentralized digital currencies - cryptocurrencies - operate, within both a practical and legal framework. The course can be broken down into three broad topics: (1) An examination of the concept of money, currency, and legal tender; (2) An introduction to the history of decentralized digital currencies, including the logic of a peer- to-peer payment system, the decentralized governance of cryptocurrency solutions, an analysis of the problems that cryptocurrencies are intended to resolve, and a high-level understanding of the blockchain; and (3) An in- depth examination and analysis of the current state of regulatory and tax treatment of various cryptocurrency transactions in the United States and in international jurisdictions.

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.

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.

Undergraduate Prerequisites: TX 901; Undergraduate Corequisites: TX 901 - 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.

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. Prerequisite: Introduction to Corporate Tax Corequisite: Partnership Tax I. Notes: Limited enrollment. Final paper.

This course undertakes a detailed examination of technology-based responses (blockchain, crypto-tax-currency, real-time transactional data collection, artificial intelligence [AI] applications) to technology-facilitated tax frauds (Zappers, Phantomware, SSaaS, the Dark Cloud and missing traders). It is valuable for both state and local as well as international practitioners, and will readily compliment criminal tax studies. This course will direct the student to consider how the sweep of technological developments in indirect taxation (digital invoices, encrypted transactional records, real-time data transmission to tax authorities, and inter- jurisdictional exchanges of digital tax data) will change/ is changing not only the collection and reporting of indirect taxes (VAT, RST, and various excise taxes) but will impact both the collection and reporting of direct taxes (personal and corporate income taxes), but also the treaties that facilitate international tax cooperation and coordination. Students should expect to be able to not only understand current technology-based tax frauds, but also be able to anticipate both the next generation of frauds, and the government's technology-based detection methods and countermeasures. Students should be able to see this as an iterative process where a technology-based fraud application is met by a government countermeasure only to find that criminal elements are fast advancing new technologies to be met yet again by more advanced government countermeasures. Public and private blockchain storage of tax data, and proposals for crypto-tax-currency based tax systems will be examined. Because this course works in a highly fluid tax/technology space the specific topics considered may not remain the same from year-to-year. This edition will examine the tax issues embedded in the technology of (1) sales suppression -- Zappers, Phantomware, SSaaS, and the Dark Cloud; (2) Missing Trader frauds -- notably frauds in CO2 permits, VOIP; and (3) excise tax avoidance -- notably frauds involved in cigarette smuggling and legalized marijuana. Both traditional organized criminal activity as well as terrorist funding activity will be explored.

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.

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.

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.

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.

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.

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.

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.

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.

This course will focus on advanced transfer pricing aspects of business restructurings (including supply chain redesigns and intangible property movements). Students will have the opportunity to experience applying the concepts of Section 482, GILTI/BEAT/FDII (new TCJA provisions) and the OECD's BEPS initiative in international tax planning for complex cross- border operations. Through case studies and small group projects, we will bring legal, accounting, and economic disciplines together to discuss practical tax challenges faced by multinational enterprises in the evolving international tax framework.

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.

This course examines the US transfer pricing system. A close reading of the Code and regulations will be expected as well as a detailed consideration of the major transfer pricing decisions. There is no other assigned text. The theme of this course is to bring students to an understanding of how the law has developed in this area focusing closely on the interplay between case law and regulatory enactments. Students should expect to encounter a reasonable amount of supporting economic and accounting analysis as they work their way through the course, and come to an appreciation of how this area of the tax law relies considerably on the blending of these three analytical perspectives.

LLCs have become the most popular entity for businesses. They are used in estate planning, joint ventures by large corporations, investment vehicles, small businesses, mergers and acquisitions, international transactions, operating businesses and individuals. This is a hands on course with lots of problem solving, drafting suggestions and practical approaches to dealing with these LLCs (emphasis on Subchapter K) within whatever tax discipline you practice. Co-requisite: Partnership Tax I

This course will focus on teaching students how to write client letters, internal memoranda, responses to IRS IDRs, and other documents common in tax practice. Students will be required to do multiple drafts of each assignment to allow for feedback and improvement on student writing. Additionally, there will be an emphasis on understanding the different audiences for each assignment (client, tax partner, government authority, etc.) and the relevant considerations in writing to each audience. Students will also be required to research and write the client letter and supporting memorandum in response to the problem set issued by the ABA Law Student Tax Challenge (submission to the competition is optional).