Master's in Taxation

This course covers the development and implementation of tax strategies. It encompasses the application of alternative tax laws to a variety of fact situations. The course applies an integrated approach to develop solutions that consider the numerous aspects of wealth maximization. Emphasizing the use of case studies, the course introduces theories and methods of tax research and analysis that include research tools, techniques and quantitative methods. Students use the university's specialized information technology resources, such as the Accounting Center for Electronic Learning and Business Measurement and the Trading Room, as well as public domain and proprietary tax databases. This course examines the role and regulation of the tax practitioner and representation of taxpayers before the IRS. Other topics include ethical responsibilities, IRS examination of returns, statutes of limitations, and tax practice strategies and techniques. Promotes teamwork, and emphasizes written and oral presentations.

This course studies federal tax law as it applies to individuals. It emphasizes the determination of gross income, deductions and credits, as well as identity of the taxable person, tax accounting and timing principles. The course introduces the tax treatment of individuals as owners of pass-through entities. It involves an in-depth analysis of the applicable tax statutes, regulations, rulings and leading court cases. Students gain an awareness of the history and tax policy considerations behind various Internal Revenue Code provisions.

This course deals with property transactions (tangible and intangible) and the ultimate tax consequences. It analyzes transactions to explore the significance of realization and recognition concepts and the characterization of gains and losses. It covers dispositions of property used in a trade or business, and held for personal use or investment, as well as deferred payment transactions. It introduces structuring the reorganization or sale of entire business units in mergers and acquisitions. It examines Internal Revenue Code provisions and selected issues that relate to determining basis, holding period, loss (active and passive) and attribute carryovers. The course also reviews transactions with the goal of conducting a thorough analysis, exploration of alternatives, and ultimate structuring to assure the desired result.

This course focuses on tax treatment of events in the life of a corporation, with special emphasis on problems at both the corporate and shareholder levels. Topics include the taxability of associations, partnerships and trusts as corporations; tax considerations in the organization and reorganization of the corporation; dividend distributions; stock redemptions; and complete and partial liquidations.

This course addresses the increased importance of international, multistate and e-business taxation in today's global environment. It introduces students to the principles guiding nexus, geographic allocation of income, and avoidance of double taxation. The course develops an understanding of the U.S. tax rules that may apply to income involving the U.S. and another country, and compares these with the multistate tax rules. It deals with the tax implications of business conducted electronically. Students use specialized information technology resources and public domain databases to conduct relevant research. The course applies multi-jurisdictional tax principles and rules to real-world case studies.

This course analyzes taxation of trusts and estates, and their creators and beneficiaries. It examines taxation of simple and complex trusts – for example, grantor trusts, irrevocable trusts and revocable trusts. Topics include trusts distinguished from corporations, distributable net income, fiduciary accounting income, the tier system, capital gains in estates and trusts, termination of estates and trusts, and administrative powers. The course considers charitable remainder trusts, pooled income funds and charitable beneficiaries, as well as planning for estate administration. Students also study income in respect of a decedent (IRD), including structural relationships, basis of IRD, relationship of IRD to distribution rules, character of IRD, and deductions.

This course provides an in-depth study of pass-through entities and problems peculiar to closely held businesses. It emphasizes students' understanding of the tax statutes, court cases and practice techniques related to the concept of "choice of entity," and creates an awareness of the potential consequences of choosing a particular form of entity. The course focuses on the practical (and tax practice) aspects of working with and advising clients on such decisions.

This course focuses on the formation, acquisition, merger, reorganization, recapitalization and divestiture transactions of business entities. It Addresses the topic of planning for transactions, with a view toward identifying the approaches that are most efficient and tax-free. The course examines Internal Revenue Code and judicial requirements that must be satisfied for successful execution of these transactions. It also reviews transaction elements (taxable and non-taxable), acceptable consideration, basis, entity attributes and carryovers.

This course explores the tax treatment of investment companies and financial products. It introduces the major types of investment and their classification for tax purposes. It focuses on mutual funds, exchange-traded funds, unit investment trusts, separately managed accounts, and offshore funds. The course analyzes the applicable special tax provisions in light of the economic function and operation of these entities. It also examines the taxation of financial products such as mutual fund shares.

Devotes attention to the tax treatment of the development, purchase, sale and licensing of intellectual properties. Specific areas of interest include computer software, research and development, the research credit, valuation of intellectual properties, amortization of intangibles, licensing, multi-jurisdictional issues, and related-party transactions. Includes an introduction to computer software, patents, trade secrets, know-how, trademarks, trade names and copyrights.

This course provides a comprehensive review of the tax issues that arise in merger and acquisition transactions. It will explore all the popular mechanisms for transferring a business – from a taxable sale of assets or corporate stock, to tax-free reorganizations, to contingent "earn out" transactions, to transactions involving an employee stock ownership plan ("ESOP"). The course examines and prepares the optimal strategies for selling a C or S corporation, an LLC (partnership), and a sole proprietorship. It examines tax strategies such as purchase price allocations under Code 1060; elections under Code 338(g) and 338(h)(10); the complicated planning strategies for an S corporation subject to the Code §1374 "Sting Tax"; the opportunities and risks of a contingent earn-out structure; the circumstances for a tax-free merger; structuring an investment by and/or sale to private equity investors; and creating a market for a company by selling shares through an ESOP.

This course considers the intricacies of the tax accounting rules and their contrast to financial accounting. It covers a range of topics that include the cash and accrual methods of accounting and the tax consequences of changing from one method to another, inventory identification and valuation, and tax depreciation with a focus on tax accounting and the major differences from financial accounting. The course deals with forgiveness of debt, passive loss rules, interest expense and the alternative minimum tax.

This course addresses the sources of state and local revenues derived from taxation, including multi-jurisdictional business excise taxes, personal income tax, consumer and transaction taxes, property taxes, and death taxes. It builds on the knowledge base developed in TX 604. Students examine constitutional restrictions on the jurisdiction to tax; allocation and apportionment of multistate income; state taxation of e-commerce; domicile concepts; and detailed review of administrative provisions related to the audit, assessment, collection and appeal of state and local taxes.

This course explores international taxation with comprehensive coverage of inbound and outbound U.S. tax issues. It expands the knowledge base developed in TX 604. The course considers the federal government's jurisdiction to tax on the basis of both residence and source of income. Topics covered include taxation of U.S. citizens abroad, individuals and corporations with resident and nonresident alien status, the concept of income effectively connected with U.S. trade or business, taxation of domestic entities doing business abroad, controlled foreign corporations, foreign tax credits, inter-company pricing, and allocation and apportionment of domestic expense. The course includes discussion of export incentives such as the Extraterritorial Income Exclusion (successor to Foreign Sales Corporations).

This course enables students to enhance their development and direction by integrating prior classroom study with the real-world experience of professional employment. Each student is required to prepare a research paper addressing a contemporary tax issue and a paper assessing the work experience, under the supervision of a faculty adviser.