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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.
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.
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.
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.
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.
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.
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.
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.
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.
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.