Course Descriptions

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  • LAW 697
    (4 Credit Hours)

    Prerequisites: RCC*; Tax I (LAW 607), or permission of instructor if concurrently registered for LAW 607. This course examines the basic rules in Subchapters C, S, and K of the Internal Revenue Code, regarding the Federal income taxation of business enterprises, whether the enterprise is organized as a corporation, partnership, or limited liability company. It includes discussion of the formation of corporations and partnerships, distributions of profits from the entity, termination of the enterprise, choice-of-entity concerns, and other related topics. It is recommended for anyone who will engage heavily in either a tax or business practice.

  • LAW 604
    (2 or 3 Credit Hours)

    Prerequisites: RCC*; Tax I (LAW 607). Topics covered include organizational structure of tax exempt and charitable organizations; policy and practice of preferred tax treatment for selected organizations and gifts to them; statutes, regulations, and IRS practice; legislative origins, judicial interpretations, and policy consideration; tests of qualification, disqualification, and limited tax preference; mechanics of securing and retaining exemption; qualified exemption; unrelated business income; private inurement; political activity; denial or loss of exemption; return and reporting requirements; private foundation treatment; comparative tax treatment of nonexempt and nonprofit organizations. Offered infrequently.

  • LAW 606
    (3 or 4 Credit Hours)

    Prerequisites: RCC*; Tax I (LAW 607) or Estates & Trusts (LAW 609). Federal gift, estate and generation skipping taxation of wealth transfers will be analyzed primarily through the concepts of completed gifts and gross estate inclusions with some study of deductions and the tax itself. Federal income taxation of estates, simple trusts and complex trusts, including distributions to beneficiaries, with some study of grantor trust rules and income in respect of a decedent will also be covered. Income taxation of trusts will be covered when the course is offered for 4 credit hours.

  • LAW 628
    (3 Credit Hours)

    Prerequisites: RCC*; Tax I (LAW 607). This course examines the U.S. Federal Income Taxation of both inbound transactions (the U.S. income tax consequences of business and investment activities in the U.S. by foreigners) and outbound transactions (the U.S. income tax consequences of foreign business and investment activities by U.S. taxpayers). It will examine, in particular, (1) the jurisdictional rules regarding the right to tax income in the international context, (2) the “source” rules (domestic or foreign) for income and deductions, (3) the foreign tax credit, (4) problem of “deferral” of foreign income earned by subsidiaries of U.S. parents, and (5) the U.S. tax consequences of using foreign currency.

  • LAW 647
    (3 Credit Hours)

    Prerequisites: RCC*; Tax I (LAW 607). This course will provide a survey of tax procedure, including the rules for practice before the IRS under Circular 230 and various tax litigation issues. The course will also provide a survey of the tax penalties and tax crimes that transactional and controversy tax practitioners must regularly consider and mange in representing private and government clients. Transactional tax advisors need to consider penalties and crimes when structuring deals and preparing opinion letters to support those deals. Without an understanding of opinion letters and the penalty or crime risks to a client’s proposed deal structure, a transactional tax attorney fails to represent his client’s interests adequately. Indeed, this lawyer and the relvant law firm may themselves be at risk. Likewise, tax controversy attorneys must have a comprehensive understanding of penalties and crimes to represent clients effectively, whether in settlement negotiations, court or administrative proceedings. These attorneys must be able to identify the range of applicable penalties and crimes, address proof convincingly and understand relevant defenses.

    Students in this class will examine relevant statutes, regulations and case law. The course will cover both the substantive law and procedural issues. Penalties addressed will include tax shelter, return preparer, responsible person, accuracy-related, delinquency and civil fraud. Methods of proof and defenses to these penalties and crimes are, of course critical to client representation and will, therefore, be covered. Satisfies the Administrative Law requirement.

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