S Corporations and Other Specially Taxed Entities
This course focuses primarily on the federal income taxation of corporations and shareholders eligible for single-tax/"pass-thru" treatment under subchapter S of the Internal Revenue Code (including the substantial interface between subchapters "C" and "S"). Significant attention is also given to (i) the use of "disregarded entities" and "check-the-box" entities in corporate structures and transactions; and (ii) the principal features of certain other special taxation regimes to which closely-held entities and their owners may be subject. Course materials include (i) pertinent provisions of the Internal Revenue Code and Treasury Regulations; (ii) assigned readings from a corporate tax treatise; (iii) selected IRS rulings, other administrative pronouncements and case law; (iv) practitioner articles and commentary; and (v) an extensive set of transactional PowerPoint slides that will serve as the primary basis for class discussion. Student grades will be evaluated based on a final examination and class participation. Course enrollment is open to all Tax LLM students and to JD students who have taken Federal Income Taxation (but not to JD students who have taken Entity Taxation).
Catalog Number: TAXLAW 602