A minimum of 26 credits are required to obtain the LL.M. degree in Taxation.
Candidates for an LL.M. in Taxation must successfully complete all required courses and sufficient electives for a minimum of 26 credit hours with a 2.50 GPA or better.
A student who has not earned at least the minimum required grade point average of 2.5 upon completion of 26 credit hours will not be awarded the LL.M. in Tax.
A student is not permitted to take extra courses to earn the required minimum grade point average of 2.5.
This course examines federal estate, gift and generation skipping transfer taxes; property included in the gross estate, including prior transfers with retained powers and interests, property subject to powers of appointment, life insurance, annuities, and jointly owned property; valuation; expenses; marital deduction; and definition of taxable gifts, including transfers in revocable and irrevocable trusts, and gifts to minors. LAW 105 Federal Income Tax is a prerequisite for this course.
The course will cover various cross-border tax planning structures, both in the inbound and outbound contexts. Inbound planning will include a discussion on financing structures, treaty planning, and the use of derivatives in cross-border planning.
Outbound planning will include the use of partnerships in international tax planning, a discussion on inversions, and advanced planning with foreign tax credits. LAW 105 Federal Income Tax, TAX 915 International Tax: Inbound and TAX 916 International Tax: Outbound are prerequisites for this course. Prerequisites may be waived at the discretion of the instructor, eg due to work experience.