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 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 (4 credits), Partnership Tax (3 credits), International Tax (3 credits), and Taxation of Financial Instruments (1 credit). The remaining nine credits will be earned in tax classes chosen by the student, 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, foreign tax credits, etc. 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.

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 of Financial Instruments

This course presents an in-depth analysis of the federal income taxation of financial instruments and transactions, with a focus on both the taxation and business aspects. In addition, selected relevant tax policy issues which the U.S. Congress, Treasury Department, and Internal Revenue Service recently have considered pertaining to financial instruments will be explored. Topics covered include: the fundamentals of debt instruments and derivatives; basic interest and original issue discount rules; market discount and premium; variable rate and contingent debt instruments; mortgage-backed securities; taxation of derivatives (options, forwards, futures, swaps and collars); hedging transactions; and cross-border aspects of financial instruments.

For course descriptions of the electives, see here:

Income Tax Treaties
Accounting for Lawyers
Tax Planning for Business
Tax Planning for Real Estate Transactions

 

 
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