Required Courses

Fall Semester

Taxation of Property Transactions
Corporate Taxation
Partnership Taxation
International Taxation
Tax Research

Spring Semester

Advanced Taxation of Property Transactions
Advanced Corporate Taxation
Advanced Partnership Taxation
Advanced International Taxation

(View the 2006-2007 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. Cameron.
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Corporate Taxation (2 units)
Considers the income tax treatment of corporations and their shareholders arising out of incorporation transfers (including transfers of liabilities), distributions, redemptions, corporate reorganizations, divisions, and corporate liquidations under the Internal Revenue Code and case law. 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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Tax Research (0 units)
Each full-time student of the Tax Program must master the “art” of tax research. Accordingly, each student will be assigned to one of the full-time tax faculty members to assist in his/her current research agenda for eight hours a week on average for the first ten weeks of the fall semester. All such activities will cease three weeks prior to the end of classes in order not to interfere with the student’s preparation for final exams. Graded on a pass-fail basis. Full-Time Tax Faculty. (Benshalom, Cameron, Crane, Postlewaite, and Wootton).
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Spring Semester Required Courses:

Advanced Taxation of Property Transactions (2 units)
Prerequisite: Taxation of Property Transactions
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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Advanced Corporate Taxation (2 units)
Prerequisite: Corporate Taxation
Considers various advanced topics in the income taxation of corporations including an introduction to consolidated returns, the taxation of hybrid investment instruments, loss carryovers and the limitations thereon, and advanced topics in the taxation of merger, acquisition, and divesting transactions. Crane.
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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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Advanced International Taxation (2 Units)
Prerequisite: International Taxation
This course examines the interplay of complex tax issues in cross-border transactions, including acquisitions and joint ventures, post-acquisition reorganizations and restructurings, and foreign tax credit planning. Crane.
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Required Courses

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