Taxation Law

6300   Federal Income Taxation (3 or 4)   K. Brown, Buchanan, Halpern, Pomerance

Survey of substantive provisions of federal income tax law, including concept of gross income, provisions affecting taxation of family and individual transactions, limitations on allowable deductions, sales and dispositions of property, problems of capital gains taxation, nontaxable exchanges. (Examination)

6302   Corporate Taxation (3)   Pomerance, C. Smith  

Continuation of Law 6300. Primary emphasis on corporate–shareholder relationships. Corporate dividends, redemptions of stock, stock dividends, bailouts, and dividends-in-kind. Federal income tax concerns involved in the formation of corporations, the sale of corporate businesses, mergers and acquisitions, and corporate divisions. Prerequisite: Law 6300. (Examination)

6304   Partnership and LLC Taxation (2 or 3)   M. Sanders

Federal income tax consequences of operating businesses taxed as flow-through entities, including partnerships, limited liability companies, and S corporations. Allocation of partnership income and deductions among partners. Issues related to contributions to partnerships, distributions from partnerships, and acquisitions and dispositions of partnership interests. Overview of the taxation of S corporations. Prerequisite: Law 6300. (Examination)

6306   Wealth Transfer Taxation (2 or 3)   Nudelman

Survey of substantive provisions of wealth transfer taxation reflecting the changing climate of federal taxation in the area of estate, gift, and income taxation, including transfers to trusts; individual, joint, and entity ownership of property; the consequences of powers of appointment or retained interest in gifted property; inter-spousal and intra-family transfers; and the application of credits and deductions to the tax picture. Prerequisite or concurrent registration: Law 6300. (Drafting assignments)

6312   International Taxation (2 or 3)   K. Brown

Federal income tax law and policy regarding foreign persons with business and investment activities in the United States (“inbound foreign investment”). Topics include jurisdiction to tax, status as foreign or U.S. taxpayer, source of income and deduction apportionment rules, withholding taxes, tax treaties and anti-treaty-shopping rules, disposition of U.S. real property by foreign taxpayers, branch profits tax, and an introduction to foreign tax credit issues. This course may also cover foreign tax credit issues, anti-income deferral rules, tax havens, and special foreign earned income rules. Prerequisite: Law 6300 or permission of the instructor. (Examination)

6314   Nonprofit Organizations: Law and Taxation (2)   Galston

Charities and other nonprofits as regulated by both federal and state laws. Tax status of nonprofits, fiduciary standards applicable to their officers and directors, liability laws for nonprofits and their volunteers, and enforcement questions. The lobbying and political activities of nonprofits, their commercial activities and the related charge of unfair competition, the extent to which nonprofits are subsidized, the justification for subsidizing them, and standing issues. Enrollment may be limited. (Examination or take-home examination at the instructor’s discretion; or research paper with the instructor’s permission)

6316   State and Local Taxation Law and Policy (2 or 3)   Brunori

Taxation by state and local governments with particular emphasis on constitutional limitations, political and economic influences on policy, and the effects of globalization and technology. Legal and policy issues of sales and use, corporate income, property, and excise taxes. (Take-home examination or research paper with permission of the instructor)

6318   Tax Policy Seminar (2)  

Intensive study of selected aspects of the tax structure with primary attention given to the federal income tax. Problem areas are reviewed primarily from the standpoint of tax policy, including legal, economic, social, and practical considerations. Alternative solutions, including current legislative proposals, are examined. Enrollment is limited. Prerequisite: Law 6300. Recommended: Law 6302. (Research paper)


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