Course Details

Partnership Tax (JD/Gen.LLM)

This three-hour course will approach partnership tax from a transactional perspective. Most weeks, the one-hour Tuesday session will be a lecture on a topic in partnership taxation. The two-hour session on Wednesday will be devoted to class discussion of one or more common (or in some cases uncommon but interesting) transactional structures that illustrate that week’s topic. Some Wednesdays, we will consider significant court cases in which the proper application of partnership tax principles has been in dispute. Students will be asked to lead and to participate in the Wednesday discussions and their grades for the course will be based partly on their success in doing so. There will also be three short papers. Topics covered during the semester will include the tax considerations involved in choosing a form of business entity, the tax treatment of contributions of property or services to a partnership, allocations among partners of partnership income and loss, the tax treatment of partnership debt and debt restructurings, partnership distributions, and partnership mergers and acquisitions. Registration Requirements: Open to 2L and 3L students and General LLM students who have completed the Basic Federal Income Tax course or its equivalent Not open to Tax LLM students Cannot be counted towards LLM in Tax or Corporate Tax Certificate If you have taken Entity Tax you should not enroll in this course. Evaluation Methods: Grades will be based on class participation and three short papers. Class Materials: Internal Revenue Code and regulations; coursebook; selected articles, cases and transactional documents

Catalog Number: BUSCOM 724


Course History

Spring 2017
Title: Partnership Tax (JD/Gen.LLM)
Faculty: Wootton, Robert R. (courses | profile)
Section: 1     Credits: 3.0
Capacity: 65     Actual: 6