Tax Procedure
|
2.0 Credits
| This course considers the rights and responsibilities of taxpayers before the IRS and in federal courts, with a focus on the overall mechanism of the voluntary compliance system and the enforcement of our federal tax laws. The class explores the procedures applicable to both taxpayers and the IRS should there be a dispute concerning the proper amount of a liability or refund. It covers topics such as the structure of the IRS and federal court system, deficiency procedures, the rights of taxpayers in the Examination and Appeals functions of the IRS, the obligation to file a tax return, refund procedures, statutes of limitation, an overview of penalties and the IRS’s power as a creditor. |
|
Wealth Tax
|
2.0 Credits
| This course will consider substantive provisions of federal estate and gift tax laws and the generation-skipping transfer tax provisions, including a review of issues relating to transfer with retention of an interest or power, joint interests, life insurance proceeds, property subject to powers of appointment, marital deductions and split gifts. The course explores the fundamental tax concepts through a rigorous application of authorities to problems. |
|
Taxation of Corporate Acquisitions and Reorganizations
|
2.0 Credits
| This course is designed to address a variety of topics including in the context of taxable acquisitions and tax free acquisitions, including a broad consideration of the non-tax business and tax issues related to taxable and tax-free transactions. With respect to taxable acquisitions, it will consider a number of issues, including (1) the tax consequences of buying and selling a business, whether S corporation or C corporation, in corporate solution; (2) the impact the sale of an asset or stock has on the seller, as well as the areas of concern for the buyer; (3) installment sales; (4) Section 1060 impact on asset sales: and (5) the impact of Section 197 on purchased intangibles. In looking at tax free reorganizations, the course will cover the various structures that qualify as ‘reorganization’ for purposes of Section 368 and the tax impact of the transactions to the corporations involved and their equity and debt holders. Prerequisite: LTX 2101: Taxation of Corporations and Shareholders. |
|
Employee Benefits
|
2.0 Credits
| This course covers the labor-law and tax aspects of the Employee Retirement Income Security Act (ERISA) coverage of employee pension and welfare benefit plans. The basic structure of ERISA and the Internal Revenue Code will be reviewed as they relate to employee benefits such as retirement plans and health and welfare plans. Topics include reporting and disclosure, preemption, fiduciary responsibility and prohibited transactions, and requirements relating to retirement-type plans (i.e., pension, profit sharing and stock bonus plans). The course will also address PBGC coverage and multi-employer plans. In addition, some other benefits frequently included as part of an employer’s benefits package will be considered. |
|
State and Local Tax: Foundations
|
2.0 Credits
| This course serves as an introduction to the basic principles of state and local taxation, and provides an overview to the various regimes of taxation used by state and local governments. This course will identify and analyze the federal limitations on the powers of the state and local governments to tax business activity within their respective jurisdictions. Topics of discussion with include the U.S. Constitution’s impact on a state’s ability to tax as limited by the Commerce Clause and the Due Process Clause, the Supreme Court’s view of nexus, and other federal statutes and regulations that affect a state’s ability to design a valid and legal taxing regime. The course also includes introductory materials on substantive aspects of state tax laws in the areas of corporate income taxes and sales and use taxes. |
|
State and Local Taxation: Income and Franchise Taxes
|
2.0 Credits
| The main focus of this course will be on the various state and local taxing regimes that affect businesses operating in corporate, pass-through and sole proprietorship format, with a primary emphasis on business income and franchise taxes. Topics include nexus and methods to evaluate current in-state activities and contacts to determine if a filing requirement exists, the unitary business concept and principles and methodologies for apportionment and allocation of revenue, and restructuring approaches to achieve organizational efficiencies and cost savings. Prerequisite: LTX 3112: State and Local Taxation: Foundations |
|
State and Local Taxation: Sales and Use and Indirect Taxes
|
2.0 Credits
| This course provides an in-depth review of the basic statutory design and implementation of an indirect sales and use tax regime, and an understanding of a taxpayer’s reporting and compliance responsibilities. The initial focus of the course will be to review and fully understand the constitutional aspects of indirect taxation. In addition, the course will address the challenges and approaches to applying the existing law with current and emerging business transactions that do not necessarily fit the tax profile of the past, such as internet sales. Additional topics include real and personal property taxes, transfer taxes, value added tax (“VAT”), and abandoned and unclaimed property. Prerequisite: LTX 3112: State and Local Taxation: Foundations |
|
State and Local Taxation: Controversy and Litigation Issues
|
2.0 Credits
| Increased pressure on state tax authorities to generate revenue has resulted in a growing number of examinations of returns and expanded audit activity, across all jurisdictions and types of tax. Frequently, this can mean significant adjustments with increased penalty potential to all forms of businesses. This course addresses the various issues that must be considered when a state tax jurisdiction has commenced an audit examination or has issued an assessment. The course will identify approaches for documenting and supporting taxpayer positions, and address strategies for managing the examination review, conducting the appeal and protest process, and planning the negotiation and litigation strategy. Prerequisite: LTX 3112: State and Local Taxation: Foundations. |
|
State and Local Taxation: Advanced Issues in Business Transactions
|
2.0 Credits
| This course addresses the various SALT issues that arise in the context of a business transaction, such as the acquisition of an existing company, the spin off or disposition of a subsidiary company or division, or a merger of two or more companies. In all of these situations, there is a significant amount of financial and tax due diligence required before the transaction is approved, and the SALT area is a major component of the tax due diligence analysis. Topics addressed in this transaction oriented course include state and local tax transaction efficiencies, resulting state tax structures and profiles, state conformity issues and other transaction related issues. In addition, the course will identify and discuss techniques and approaches used to uncover potential SALT liabilities and exposures. Prerequisite: LTX 3112: State and Local Taxation: Foundations. |
|
Taxation of Trusts and Estates
|
2.0 Credits
| This course addresses federal income taxation of trusts and estates, including the decedent’s final return, income and deductions in respect of a decedent, the conduit concept for taxing beneficiaries, the separate share rule, the throw-back rules, grantor trusts and income tax deduction elections interrelated with the federal estate tax. Prerequisite: LTX 3111: Wealth Tax. |
|