Required Courses

In addition to the required courses described below, all students must complete at least one additional course in international taxation by enrolling in one of the following courses:

  • Transfer Pricing (fall semester)
  • Controlled Foreign Corporations (spring semester)
  • Advanced International Corporate Tax Problems (spring semester)
  • International Estate Planning (spring semester)
  • Tax Treaties (spring semester)

Descriptions of these courses are available on the Elective Courses web page.

Fall Semester

Spring Semester

(View the Course Schedule (pdf))

Fall Semester Required Courses:

Taxation of Property Transactions (2 units)
Considers the federal income tax aspects of the acquisition, ownership, and disposition of tangible and intangible property including concepts of realization and recognition of income and loss; basis of purchased property and the basis of property acquired by gift or by bequest; determination of the amount realized; acquisition and disposition of property subject to liabilities; like-kind exchanges and other non-recognition transactions; tax shelters and at-risk, passive activity, and other limitations on loss recognition; basis adjustments; the effect of depreciation and recapture; mechanics of capital gains and losses; installment sales; open transactions; imputed interest; and original issue discount. Further consideration of the tax and economic issues arising in property transactions, with particular attention devoted to structuring transactions to achieve tax benefits. Significant attention will be devoted to issues arising in the sale of a business. Consideration will be also given to carve-out and lease stripping transactions and the distinctions between sales, licenses, leases, and financing arrangements. Cameron.
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Corporate Taxation (2 units)
This course focuses primarily on the provisions of subchapter C of the Internal Revenue Code as they relate to the federal income tax consequences to corporations and their shareholders of transfers of property and liabilities into corporations, dividend distributions, redemptions, liquidations, taxable stock and asset acquisitions and certain tax-free reorganizations. Coverage is also given to subchapter S corporations and certain other special corporate tax regimes. Crane.
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Partnership Taxation (2 units)
Considers the federal income tax treatment of partnerships and limited liability companies classified as partnerships, contributions to and distributions from partnerships, partnership operations, substantial economic effect regulations and special allocations, transfers of partnership interests, taxation of service partners, shifting of liabilities among partners, special basis adjustments, and terminations. Wootton.
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International Taxation (2 units)
Considers the principles and underlying policies of the United States taxing system concerning: (1) income earned by United States citizens, resident aliens, and corporations from business and investment activities abroad and (2) income earned by nonresident alien individuals and foreign corporations from business and investment activities in the United States. The course will examine basic international tax jurisdiction issues; source of income and allocation and apportionment of deduction rules; the taxation of foreign persons' United States trade or business income, non-business income from United States sources, and the sale of United States real property interests; an introduction to the foreign tax credit provisions; the foreign earned income exclusion in §911; the role of tax treaties; and an introduction to Subpart F and the other so-called "anti-deferral" mechanisms. Postlewaite.
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Spring Semester Required Courses:

Advanced Taxation of Property Transactions (2 units)
Prerequisite: Taxation of Property Transactions
Description coming soon.
Cameron.
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Advanced Partnership Taxation (2 units)
Prerequisite: Partnership Taxation
This course considers formation issues in the utilization of the partnership vehicle including issues regarding the allocation of nonrecourse liabilities and deductions attributable thereto, the use of special allocations, the tax consequences of contributing property with built-in gains and losses, the admission of a partner to an ongoing partnership, and the compensation and equity participation of partners. Additionally, issues involving exit strategies from a partnership are explored including the §758 election and the §§734(b) and 743(b) adjustments, the application of §751(b), the maximization of capital gain treatment, and the effective use of §736. Finally, the course addresses the use of international tax partnerships and the uncertainty involved in the integration of Subchapter K and the international provisions. Tax treaty issues and entity classification issues, particularly respecting hybrid entities, are explored in depth. Wootton.
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Related Links

Tax Faculty | Required Courses| Elective Courses | CourseSchedule (pdf)