Curriculum

Unlike the general LL.M., the International Tax LL.M. has a specific set of requirements designed to ensure the highest-level educational and practical experience.

To obtain the International Tax LL.M, students must complete a total of 24 credits with at least a 3.0 ("B") average in two terms of residence. More specifically, International Tax LL.M. students must take the following Law School courses: Taxation of Individual Income (4 credits), Corporate Tax (3 credits), Partnership Tax (3 credits), International Tax (3 credits), and the Tax Policy Workshop (or a similar advanced course) (3 credits). The remaining eight credits will be earned in tax classes chosen by the student (such as Income Tax Treaties, Taxation of Financial Instruments, or Taxation of Business Transactions), in approved classes in a related field, and by writing a tax law research paper under the supervision of one of the International Tax Program faculty.

Courses

International Tax

This is an introduction to U.S. taxation of U.S. and foreign persons engaged in international activities. Topics include U.S. jurisdiction to tax, tax treaties, allocation of income, transfer pricing, and foreign tax credits. The class addresses some of the important procedural mechanisms by which international tax issues are resolved, e.g. advanced pricing agreements and Competent Authority negotiations. This class provides an overview of the relevant law, giving due respect to its complexity and the policies underlying it, identifying and wrestling with the types of issues that most frequently arise.

Economics of the Public Sector

This course analyzes the role and effect of government fiscal policy on the economy. The course focuses on microeconomic issues and, while presenting a theoretical framework for understanding the effects of government, is also concerned with evaluating the performance of governments. Much of the class discussion will be devoted to consideration of public policy issues that are currently under debate in the U.S. and elsewhere. Specific topics to be covered include the effects of spending on public infrastructure and public education, health insurance and the market for medical care, cost-benefit analysis of government programs, and various issues in tax policy: income distribution, taxation of the family, environmental taxation, IRAs and saving, taxation of capital gains, corporate taxation, tax incidence, tax reform, enterprise zones, and international taxation.

Corporate Taxation

This course concentrates on the provisions of the Internal Revenue Code bearing on domestic corporations. It deals with the tax consequences to corporations and their shareholders as a result of the events that take place during a corporation's life span. For example, the course examines the tax consequences that can arise on the formation of the corporation, distribution of assets from the corporation, sales of corporate stock, reorganizations and divisions, and liquidations. The course also examines the extent to which the tax attributes of a corporation can be acquired by another corporation.

Partnership Tax

This course covers the provisions of the Internal Revenue Code that deal with partnerships. The course covers such items as the definition of a partnership for tax purposes; the utilization and importance of a "balance sheet" analysis of partnership activities; the question of whether a partnership is treated as an entity or as an aggregate of separate interests; the transfer of assets to and from a partnership; the allocation of partnership tax attributes; the special treatment of recourse and nonrecourse liabilities; the operation of a partnership; the determination of a partnership's basis in its assets and a partner's basis in the partnership interest; the restrictions on the deductibility of a partner's share of partnership losses; the effect of a change in partnership interests; and the disposition of partnership interests.

Taxation of Individual Income

This is the basic course in federal income taxation. It is a statutory course, and the principal source of law will be the Internal Revenue Code. Topics covered include the definition of gross income and the determination of permissible deductions from gross income; analysis of numerous Code provisions and doctrines that raise issues of tax timing (in what year should a given item of income or a given deduction be taken into account) and income attribution (to whom should a given item of income or a given deduction be attributed). The course focus is learning basic statutory analysis and studying the policy rationales underlying the structure of the current federal income tax laws, and considering the pros and cons of alternative systems.

Tax Policy Workshop

This workshop features prominent tax scholars from law schools around the country, as well as public finance economists and tax practitioners, all of whom will be presenting current research on tax policy. Students are expected to read the papers, submit written comments, and participate in the discussions.