Details

This course will provide a student with a comprehensive framework for analyzing the tax issues with respect to financial products and derivatives. The class will explore the theoretical underpinnings of these products, with a view to understanding how they are woven from the overall body of tax law, including the Code, Treasury Regulations, and case law. Emphasis will be placed on developing analytical tax skills so that students can better understand the interplay between the broad array of anti-abuse rules, elections, and identifications that make up the hodgepodge of tax rules governing the taxation of financial products. Additionally, there will be an in-depth study of popular financial products (including ¿ 1256 contracts, forward contracts, options, swaps, and caps) and those currently offered in the marketplace, as well as a focus on mandatory and elective mark-to-market rules, the constructive sale rules, the straddle rules, wash sale and short sale rules, and the tax rules applicable to foreign currency transactions (including currency hedging). Pre-requisite: Not open to second year JD students who are not enrolled in the Joint Degree Program without the permission of the instructor. Basic Federal Income Tax is a pre-requisite for JD candidates.