Required Courses

Fall Semester

  • Corporate Taxation (2 credits)
  • International Taxation (2 credits)
  • Partnership Taxation (2 credits)
  • Taxation of Property Transactions (2 credits)

Spring Semester

  • Advanced Partnership Taxation (2 credits)
  • Advanced Taxation of Property Transactions (2 credits)

Students must choose one of the following elective courses to fulfill the Advanced Corporate Tax requirement:

  • Consolidated Returns (2 credits)
  • Corporate Reorganizations (2 credits)
  • Divisive Reorganizations and Separations (2 credits)
  • Executive Compensation (2 credits) — course available during fall semester
  • Subchapter S Corporation — course available during fall semester
  • Tax Aspects of Private Equity Transactions (2 credits)
  • Taxation of Debt Instruments and Other Transactions (2 credits)

Students must choose one of the following elective courses to fulfill the Advanced International Tax requirement:

  • Advanced International Corporate Tax Transactions (2 credits)
  • Controlled Foreign Corporations (2 credits)
  • European Union Taxation (2 credits)
  • International Estate Planning (2 credits)
  • International Taxation of Partnerships (2 credits)
  • Tax Treaties (2 credits)  course available during the fall semester
  • Transfer Pricing (2 credits)  course available during the fall semester

Fall Semester


Corporate Taxation (2 credits)
This course focuses primarily on the federal income tax treatment of “C” corporations and their shareholders in connection with transfers of property and liabilities into corporations, dividend distributions, redemptions, liquidations and taxable stock and asset acquisitions. Significant coverage also is given to the special elective single-tax/pass-thru regime applicable to eligible “S” corporations. Pencak.

International Taxation (2 credits)
The objective of this course is to familiarize students with the principles and underlying policies of the United States taxing system concerning: (1) income earned by United States citizens, residents, and corporations from business and investment activities abroad and (2) income earned by non-resident alien individuals and foreign corporations from business and investment activities in the United States. The course considers the 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, including the concepts of "United States trade or business" and "effectively connected income"; the taxation of foreign persons' non-business income from United States sources, including the concept of "fixed or determinable annual or periodical gains, profits, and income" and the United States tax rules with respect to the sale of United States real property interests; an introduction to the foreign tax credit provisions; the foreign earned income exclusion in section 911; the role of tax treaties; and an introduction to Subpart F and the other so-called "anti-deferral" mechanisms. Pencak.

Partnership Taxation (2 credits)
This course 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. Postlewaite and Rosenberg.

Taxation of Property Transactions (2 credits)
The first half of the course 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; capitalization; cost recovery; acquisition and disposition of property subject to liabilities; mechanics of capital gains and losses; the effect of depreciation and depreciation recapture; installment sales and open transactions; imputed interest, and original issue discount. The second half of the course considers limitations on tax shelters and tax-structured transactions including the at-risk, passive activity, and other limitations on loss recognition; limitations on interest deductions; and the tax treatment of leasing transactions including the business purpose and economic substance doctrines, rent-leveling, and loss limitations. Tokic.

Spring Semester

Advanced Taxation of Property Transactions (2 credits)
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 given to carve-out and lease stripping transactions and the distinctions between sales, licenses, leases, and financing arrangements. Tokic.

Advanced Partnership Taxation (2 credits)
Prerequisite: Partnership Taxation
This course explores selected, advanced issues in the Federal income taxation of partnerships and limited liability companies and their owners. Topics considered include the application of section 704(c) to built-in gains and losses arising from property contributions and from revaluations of partnership property, the treatment of non-compensatory and compensatory options, the disguised-sale rules, the allocation of nonrecourse debt and nonrecourse deductions, the current tax treatment of carried interests, the pitfalls and opportunities presented by basis-shifting distributions, and partnership mergers and divisions. Partnership capital accounting is employed extensively throughout the course to illustrate and explain the statutory rules and possible tax-planning responses. Postlewaite and Rosenberg.

Related Links

Fall Course Schedule (pdf)
Spring Course Schedule (pdf)