Levin College of Law

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  • Download the current Graduate Tax Program catalog.  

    Graduate Tax Curriculum

    The Graduate Tax Program offers an outstanding curriculum to its students. The courses are taught almost exclusively by full-time members of the tax faculty and the courses typically are restricted to Graduate Tax students.

    The curriculum involves intensive study and preparation, and the full-time structure of the program enables students to work with each other and consult their professors outside the classroom.

    Taxation of Property Transactions

    Tax problems of individual taxpayers; problems incident to the sale, exchange, and other disposition of property, including recognition and characterization concepts.

    Timing Issues in Taxation

    Income tax accounting principles and problems; the taxable year; accounting methods; delayed payment transactions; time value of money.

    Civil Tax Procedure

    Taxpayers’ relationships with the Internal Revenue Service, including requests for rulings, conference and settlement procedures; deficiencies and their assessment; choice of forum; tax court practice; limitation periods and their mitigation; transferee liability; tax liens; and civil penalties.

    Federal Tax Research

    Substantial research and writing project on a federal tax subject; instruction in tax research techniques. Seminars are offered to satisfy this requirement.

    Corporate Taxation I

    Tax considerations in corporate formations, distributions,redemptions, and liquidations, including Subchapter C and Subchapter S corporations. Some general consideration of the tax alternatives relating to the sales of corporate businesses.

    Corporate Taxation II

    Prerequisite: Corporate Taxation I or Instructor’s consent. Corporate reorganizations; corporate acquisitions and divisions, including transfer or inheritance of losses and other tax attributes; corporate penalty taxes; consolidated returns provisions.

    U.S. International Tax I

    The tax definition of resident; the distinction between domestic and foreign entities; taxation of business income and nonbusiness income of foreign persons; taxation of income of trades or businesses carried on by foreign persons in the U.S.; special rules on U.S. real property interests; and branch profits and branch interest taxes.

    U.S. International Tax II

    The foreign tax credit; special rules on controlled foreign corporations; foreign currencies; and cross-border transfers in nonrecognition transactions.

    Partnership Taxation

    Tax meaning of “partnership”; formation transactions between partner and partnership; determination and treatment of partnership income; sales or exchange of partnership interest; distributions; retirement; death of a partner; drafting the partnership agreement.

    Federal Taxation of Gratuitous Transfers

    Federal estate, gift and generation-skipping transfer taxes.

    Income Taxation of Trusts & Estates

    Taxation of income of trusts and estates, including simple and complex trusts, annuities, property distributions, income in respect of a decedent, grantor trusts.

    Estate Planning

    Planning lifetime and testamentary dispositions of property; postmortem planning; analysis of small and large estates; eliminating and offsetting complicating and adverse factors; selection of a fiduciary and administrative provisions.

    Deferred Compensation

    Tax consequences of compensation in forms other than cash paid contemporaneously with performance of the services. Includes nonqualified deferred compensation devices, and qualified pension and profit-sharing plans.

    Tax Exempt Organizations

    A study of the exemption from federal income tax accorded to a variety of public and private organizations, and the tax treatment of contributions to such organizations; public policies underlying exemption from tax and deductibility of contributions.

    Procedures in Tax Fraud Cases

    Criminal offenses and methods of proof; investigative authority of the IRS; summons enforcement proceedings; search warrants and grand jury subpoenas; constitutional defenses to the compulsory production of evidence; attorney-client privilege, and other objections available to taxpayers and third parties.

    State & Local Taxation

    Nature and purpose of state taxation; comparison of property and excise taxes; uniformity of taxation; assessment and collection procedures; remedies available to taxpayers.

    Comparative Taxation

    A comparative study of tax systems of the world, including income and wealth transfer taxes and taxes on consumption. Primary emphasis is on basic structural features and policies.

    Tax Policy

    Examination of the principal criteria used to make choices on forms of taxation and the impact of tax provisions on type and location of business and investment activities. Content may vary.

    Tax Treaties

    Bilateral income tax conventions between countries to alleviate double taxation of income from international investments and activities and to provide for exchanges of tax information and consultation between tax authorities.

    Transfer Pricing

    Transactions between related entities in connection with the tax requirement that such transactions be priced as if between unrelated persons.

    International Tax Planning

    Examination of the tax consequences of proposed cross-border business transactions that are subject to the rules of multiple taxing jurisdictions.

    Financial Instruments

    Taxation of income from financial instruments of various kinds, including options, futures, forwards, swaps, and other instruments often referred to as “derivatives.”

    Mergers and Acquisitions Involving International Corporations

    An application of materials studied in U.S. International Taxation II to merger and acquisitions transactions.

    Current Federal Tax Problems

    Significant current developments in tax law, often with emphasis on policy considerations. Course content and coverage vary.

    Independent Study

    Students may be allowed to pursue an independent study project under supervision of a tax faculty member, subject to approval of the director.

    Note: Course offerings vary from year to year. Contact the Graduate Tax Office for information on current courses.