Courses - Taxation LL.M.

Program Requirements

A minimum of 26 credits are required to obtain the LL.M. degree in Taxation.

Students may take a maximum of one, two-credit Independent Study and have it count toward their LL.M. degree in Taxation elective requirements.

If a student is accepted into the four-credit Independent Study/IRS Internship, then all four credits will count toward the LL.M. degree.

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.

Please note that Orientation is mandatory for all students entering the Graduate Program in Taxation.

Concentration Requirements

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  • International Tax

    Students who meet the requirements will have a "Concentration in International Tax" noted on their transcripts. Courses that the student audits do not count towards any concentrations, or towards the credits required for the LL.M. degree.

    Other than the courses that are required for the LL.M. degree, no course can be counted towards more than one concentration.  If a course could otherwise be counted towards more than one concentration, the student can choose which such concentration the course can count towards.

    • Students must complete at least 8 credits in international tax courses in our program.
    • The required international tax courses for our Tax LL.M. program - International: Inbound (2 credits) and International: Outbound (2 credits) – count towards these 8 credits.
    • Students wishing to obtain the Concentration in International Tax must take an additional 4 credits covering specialized topics within the international tax field beyond these required courses. 
    • Additional courses they can choose from include:
      • Income Tax Treaties (1 or 2 credits)
      • International Transactions: Europe (1 credit)
      • International Transactions: Latin America (1 credit)
      • Representing High Net Worth Individuals (2 credits)
      • International Tax Problems (2 credits)
      • Introduction to U.S. International Tax Policy (1 credit)
      • Taxation of Global Shipping Operations (2 credits)
      • Cross Border Taxation of Financial Instruments (1 credit)
      • New International Tax Consensus: OECD's "Pillar One" and "Pillar Two" Proposals (1 credit)
      • Advanced International Tax Planning (1 credit)
      • Tax Issues Relating to Movement of Foreign Tech Founders into Miami in the 21st Century (1 credit)

    Students must obtain a 2.5 GPA or higher for all international tax courses counting toward this concentration.

    Other electives may be offered from time to time. Not all electives may be offered every year.

  • Taxation of High Net Worth Individuals

    Students who meet the requirements will have a "Concentration in Taxation of High Net Worth Individuals” noted on their transcripts. Courses that the student audits do not count towards any concentrations, or towards the credits required for the LL.M. degree.

    Other than the courses that are required for the LL.M. degree, no course can be counted towards more than one concentration.  If a course could otherwise be counted towards more than one concentration, the student can choose which such concentration the course can count towards.

    • Students must complete at least 8 credits of the courses listed below.
    • One required course for our Tax LL.M. program – Federal Wealth Transfer Tax (2 credits) - counts towards these 8 credits.
    • Students must also take the course on Representing High Net Worth Individuals (2 credits).
    • Students wishing to obtain the Concentration in Taxation of High Net Worth Individuals must take an additional 4 credits covering specialized topics relating to taxation of high net worth individuals, beyond the two required courses listed above. 
       
    • Additional courses they can choose from include:
      • Estate Planning (1 credit)
      • Income Tax of Trusts and Estates (3 credits)
      • Federal Criminal Tax Practice (1 credit)
      • Taxation of Executive Compensation (2 credits)
      • Taxation of Athletes and Entertainers (1 credit)
         

    Students must obtain a 2.5 GPA or higher for all courses counting toward this concentration.

    Other electives may be offered from time to time. Not all electives may be offered every year.

  • Business Taxation

    Students who meet the requirements will have a "Concentration in Business Taxation" noted on their transcripts. Courses that the student audits do not count towards any concentrations, or towards the credits required for the LL.M. degree.

    Other than the courses that are required for the LL.M. degree, no course can be counted towards more than one concentration. If a course could otherwise be counted towards more than one concentration, the student can choose which such concentration the course can count towards

    • Students must complete at least 10 credits in business taxation courses in our program.
    • The required business taxation courses for our Tax LL.M. program – Corporate Tax (2-3 credits) and Partnership Tax (2-3 credits) –  count towards these 10 credits.
    • Students must also take the course on Transactions Involving Consolidated Groups (2 credits).
    • Students wishing to obtain the Concentration in Business Taxation must take an additional 4 credits covering specialized topics within the Business Taxation field beyond the three required courses listed above. 
       
    • Additional courses they can choose from include:
      • Corporate Tax II (1 credit)
      • Introduction to Financial Instruments (1 credit)
      • Cross-Border Taxation of Financial Instruments (1 credit)
      • Limitations on Loss Utilization (1 credit)
      • Partnership and Property II (1 credit)
      • Tax Accounting (2 credits)
         

    Students must obtain a 2.5 GPA or higher for all business tax courses counting toward this concentration.

    Other electives may be offered from time to time.  Not all electives may be offered every year.

Required Courses

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  • Federal Wealth Transfer Tax (2 credits, TAX 946; Nichole Scott)

    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;
    • Definition of taxable gifts, including transfers in revocable and irrevocable trusts, and gifts to minors

  • International: Inbound (2 credits, TAX 915; Michael Bruno)

    This course analyzes the taxation of foreign persons in the United States, including taxation of United States real property interests and withholding on the disposition or acquisition of business interests in the United States; related issues such as choice of entity and sales of goods imported into the United States; and pre-immigration tax planning strategies.

  • International: Outbound (2 credits, TAX 916; Jeffrey Rubinger)

    This course examines the income taxation of investments made outside the United States by U.S. persons, including investments in controlled foreign corporations and passive foreign investment companies; the foreign tax credit provisions; foreign derived intangible income; and cross-border reorganizations.

    Federal Income Tax and International: Inbound are prerequisites for this course. Corporate Tax OR Corporate Tax I and Partnership Tax are recommended before taking this course. TAX 915 International: Inbound is a prerequisite for this course. The prerequisite requirement can be waived by director. TAX 905 Corporate Tax I or TAX 948 Corporate Tax and TAX 950 Partnership Tax are recommended prior to taking this course. Open to JD students with the permission of Tax LL.M. Director.

  • Corporate Tax I (2 credits, TAX 905; Dana Trier)

    This course presents an introduction to the U.S. federal income tax treatment of corporations under Subchapters C and S of the Internal Revenue Code. The course will first address certain common transactions under Subchapter C, including contributions of property to the corporation in exchange for stock, nonliquidating distributions of cash or other property by the corporation, redemptions of stock and corporate liquidations. Then the course will provide an introductory overview of the taxation of S Corporations and the planning issues commonly encountered with respect to S Corporations. Tax free reorganizations and tax free spinoffs will only be introduced briefly in this course.

  • Partnership Tax (3 credits, TAX 950; Rebecca Rosenberg)

    This course examines the federal income tax consequences of partnership formation and operation, partnership distributions in cash or in kind, withdrawal from partnerships, sale of partnerships, and sale of partnership interests and assets, including definition of a partnership, special allocations of partnership income and losses, the effect of liabilities and a comparison with similar consequences for S corporations. LAW 105 Federal Income Tax is a prerequisite for this course. Open to JD students with the permission of Tax LL.M. Director.

  • Property Transactions (1 credit, TAX 949; Sergio Garcia-Pages)

    The aim of this course is to provide students with a graduate level understanding of the rules and principles relating to the federal income tax consequences of property transactions involving borrowings, sales, gifts and inheritances. Topics covered include when income is "realized" in property exchanges in kind, what is a "sale," what is a "disposition," what are the different "cost basis" rules, how non-recourse and recourse indebtedness affect the realization and amount of gain or loss, character of gain or loss as capital or ordinary, selective statutory provisions that limit the use of losses realized or change the character of gain realized from capital to ordinary in transactions between related parties, and statutory limitations on methods of accounting. These issues will be explored through analysis of materials, problems and class discussions in which students are encouraged to actively participate without inhibition. The rules and principles covered in this course are the predicate for understanding partnership and corporate income taxation.

Elective Courses

Note: Not all elective courses may be offered every year.

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  • Advanced International Tax Planning (1 credit, TAX 920; Jeffrey Rubinger)

    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. International Tax: Inbound and International Tax: Outbound are prerequisites for this course. Prerequisites may be waived at the discretion of the instructor, eg due to work experience.

  • Corporate Tax II (1 credit, TAX 990; Dana Trier)

    The core topics covered in this course include: the tax economics of taxable asset and stock transactions; section 338(h)( 10) transactions, including public 338(h)(10) transactions; the basic requirements relating to to tax-free reorganizations; triangular tax-free reorganizations; the use of Section 351 as an acquisition technique in so-called double dummy transactions; management rollover transactions; the step transaction doctrine and its effect on acquisition forms; and, time permitting, spinoffs. The close perusal of key corporate tax revenue rulings is emphasized. This course will address the topics covered at a more sophisticated level than a first semester corporate tax class.   Corporate Tax (or similar course, such as Taxation of Business Entities, with permission of the instructor) is a prerequisite for this course. Prerequisite may be waived by the instructor, eg in case of relevant professional experience.

  • Transactions Involving Consolidated Groups (2 credits, TAX 912; Kevin Hennessey)

    This course focuses on the many special rules affecting affiliated corporations which file a consolidated return. It explores issues relating to the formation of the consolidated group, its intercompany transactions, the affect of tax attributes involving the acquisition and disposition of members as well as the unique treatment of many Code sections that affect corporations. Corporate Tax or Corporate Tax I is a prerequisite for this course.

  • Federal Criminal Tax Practice (1 credit, TAX 954; Scott Michel)

    This course examines the substantive, procedural and tactical aspects of the criminal aspects of the federal tax system. The IRS and the Justice Department prosecute criminal tax cases each year involving a variety of fact patterns, from the simple, such as the failure to file tax returns or report income, to the complex, such as the implementation by tax advisors of unlawful tax schemes.

    An understanding of the criminal tax enforcement function is important to any tax lawyer doing controversy work, tax planners who might work on sophisticated planning issues, and practitioners in the international area. Topics will include:

    1. The nature and types of criminal tax offenses
    2. Government processes and policies underlying criminal tax enforcement cases
    3. The prosecution and defense of criminal tax cases from inception through trial
    4. Plea bargaining and sentencing in tax cases
    5. The intersections between civil and criminal tax compliance and enforcement
    6. The IRS voluntary disclosure policy
    7. Ethics issues relating to criminal tax cases.
    Course materials will include selected Code provisions, cases, and government policy and procedures.

  • Cross Border Taxation of Financial Instruments (1 credit, TAX 985; Jeffrey Rubinger)

    These instruments are contractually defined interests in business entities that are neither debt nor equity, although they may have certain features of each. Taxation of these financial products is subject to substantial uncertainty and complexity, especially in the cross-border setting where they are utilized as a tool for speculation as a well as hedging.

    This course explores the cross-border tax issues relating to a range of financial instruments, including total return swaps, forward contracts, options, and equity-linked debt instrument . Corporate Tax and Taxation of Financial Products are prerequisites.

  • Estate Planning (1 credit, TAX 958; Christopher Boyett)

    This course takes a practical approach to the estate planning process, analyzing typical fact patterns encountered in practice. Planning for younger families, affluent retirees, and owners of family businesses is discussed, and ethical considerations, such as conflicts that arise from dual representation of husband and wife, are also considered.

  • Federal Tax Procedure (2 credits, TAX 943; Karen Lapekas)

    This course covers major aspects of tax procedure, tax controversy, and tax dispute resolution. It also includes an in-depth analysis of the United States Tax Court tax litigation process.

    The analysis encompasses the organization and jurisdiction of the courts, choice of forum, pleadings, problems in major cases, partnership litigation, the trial process (particularly with respect to discovery, stipulations of facts, burden of proof, and evidentiary questions), briefs, the decisional process, and post-trial activity (including attorney's fees and appeals).

  • Representing High Net Worth Individuals (2 credits, TAX 917; Jennifer Wioncek)

    This course deals with inbound and outbound tax issues encountered in representing high net worth individuals/private clients. The following topics are covered in depth: The Concept of Residency for U.S. Income Tax Purposes and Its Application When Advising High Net Worth Individual Clients, U.S. Transfer Tax Considerations For the International Private Client Advisor, Advising Nonresidents with Active Operations in the United States, Advising Nonresidents with Real Estate Investments in the United States, Check the Box Planning, Advising Nonresidents with Passive Investments in the United States, Planning with Trusts (Part I) – Grantor, Planning with Trusts (Part II) - Non-Grantor Trusts, Pre-Immigration Planning (or Post-Immigration Clean-up), Advising U.S. Private Clients with Investments Outside of the US; Expatriation, and International Tax Compliance. Prerequisites: Property Transactions, either Taxation of Business Entities OR both Corporate Tax and Partnership Tax, Taxation of Trusts and Estates, Federal Wealth Transfer Tax, International: Inbound, International: Outbound. Note: if they receive the permission of the Director, students who are planning to graduate at the end of this Spring 2023 semester can take the following courses as co-requisites rather than pre-requisites: Partnership Tax, Taxation of Trusts and Estates, International: Outbound.

  • Income Tax Treaties (1 or 2 credits, TAX 973)

    This course focusses on the analysis and interpretation of the typical provisions of bilateral tax treaties. It does so on the basis of the OECD and UN Model Tax Conventions and in the light of the U.S. Model Income Tax Convention. The course discusses common planning methods utilizing tax treaties, as well as common anti-abuse rules found in these treaties. TAX 915 International: Inbound is a prerequisite for this course.

  • Income Taxation of Trusts and Estates (3 credits, TAX 910; John Anzivino / Mark Scott)

    In this course students study the income taxation of estates, trusts, and their beneficiaries; computation of fiduciary accounting income pursuant to Florida Principal and Income Statutes 738, distributable net income; distribution deductions for simple trusts, complex trusts and estates; distributions in kind; planning for funding of bequests outright and in trust; income in respect of a decedent; the grantor trust rules; 65 day election under 663(b);  election to recognize gain on residual distributions under 643(e); charitable income tax deduction under 642(c); Section 265 allocation of expenses to tax exempt income; and related income tax basis rules. LAW 105 Federal Income Tax is a prerequisite for this course. Open to JD students with the permission of Tax LL.M. Director.

  • International Transactions: Europe (1 credit, TAX 918; Christian Wimpissinger / Andrew Solomon)

    This course provides an introduction to European Union tax law and how tax planning for U.S. multinational groups can be affected by foreign tax law. This condensed course is co-taught by European and U.S. tax lawyers. It introduces important concepts in European Union tax law and describes the most important EU Directives regarding direct taxation as well as case law of the ECJ in the context of common cross-border fact patterns, including acquisitions, reorganizations, and financing structures. TAX 915 International: Inbound is a recommended prerequisite for this course. TAX 916 International: Outbound is a recommended corequisite for this course. Open to JD students with the permission of Tax LL.M. Director.

  • International Transactions: Latin America (1 credit, TAX 930; Ricardo Escobar / Matthew Berman)

    This course provides an introduction to techniques used by international tax planners in an environment where there are an increasing number of tax treaties and significant taxes in addition to income taxes. This condensed course is co-taught by Latin American and U.S. tax lawyers. It focuses on practical case studies regarding the structure of U.S. investments into Latin America but will also discuss some issues involving Latin American investments into the United States. Issues addressed will include structuring sales and services operations, options regarding mergers and acquisitions and issues concerning the repatriation of funds. TAX 915 International: Inbound and TAX 905 Corporate Tax I or TAX 948 Corporate Tax are prerequisites for this course. Open to JD students with the permission of Tax LL.M. Director.

  • Introduction to Financial Instruments (1 credit, TAX 984; Jeffrey Maddrey)

    Financial instruments are contractually defined interests in business entities that are neither debt nor equity, although they may have certain features of each. Taxation of these financial products is subject to substantial uncertainty and complexity. This course explores the tax issues relating to a range of swaps and derivatives and other contractually defined interests. Corporate Tax is a prerequisite.

  • Limitations on Loss Utilization (1 credit, TAX 922; Kevin Hennessey)

    This course covers the many Code sections which limit the use of net operating losses including Sections 269 and 382, at risk and passive loss limitations, as well as the special rules affecting cancellation of indebtedness and worthless stock. LAW 105 Federal Income Tax is a prerequisite for this course. Open to JD students with the permission of Tax LL.M. Director.

  • State and Local Taxation (1 credit, TAX 977; Charles Mercer / Reed Hollander)

    This course examines the constitutional limitations, including Due Process and Commerce Clause restrictions, on state and local taxing authority; provides an overview of three main areas of state and local taxation: income/franchise tax, sales and use tax, and property tax; and explores the practical aspects of contesting audits and assessments before tax officials and tribunals.

  • Tax Accounting (2 credits, TAX 968; Luis Arritola)

    This course addresses the fundamental issue of accounting, namely, the time when items of revenue and expense are taken into account. It covers annual accounting, the tax year, accounting methods, asset cost recovery, interest and proxies therefore, and installment sales. LAW 105 Federal Income Tax is a prerequisite for this course and must have received a “B” or better in the course. Open to JD students with the permission of Tax LL.M. Director.

  • Taxation of Global Shipping Operations (2 credits, TAX 927; James R. Border)

    Students will learn the basics of international transportation operations with an emphasis on maritime transportation, national and international regulation, and how various countries tax shipping operations.  United States federal and state tax provisions and those of other countries will be analyzed and compared. The application and impact of tax treaties, transportation agreements and the UN Convention on the Law of the Sea on income and other taxes imposed on shipping and necessary to an understanding of the structure of global shipping operations will be reviewed. Non-tax maritime considerations will be introduced for a broader understanding of the industry. The course will address both current taxation of shipping and the pending proposals at the OECD, United Nations, European Union, and other international bodies. LAW 105 Federal Income Tax is a prerequisite for this course. Open to JD students with the permission of Tax LL.M. Director

  • Partnership and Property II (1 credit, TAX 991; Dana Trier)

    The topics discussed in this course include: the disguised sale rules, particularly the application of such rules to formation of real estate partnerships and UPREIT structures; the mixing bowl rules; partnership termination and related classic revenue rulings such as Rev. Rul. 99-5 and 99-6; the carried interest rules; Section 199A; and the Section 163(j) interest deductibility limitation and its applicability to real estate and partnerships.

  • Taxation of Executive Compensation (2 credits, TAX 908; Dana Trier)

    This course covers the U.S. federal income tax rules relating to the compensation of executives and other highly compensated service providers. After an introductory conceptual overview of the tax economics of deferred compensation and the core rules relating to such compensation, the course will address four basic topics: the tax regimes governing defined benefit pension plans,
    section 401(k) plans and other tax favored benefits; the statutory provisions applicable to nonqualified cash compensation, including section 409A of the Code; the tax treatment of equity based compensation, with a particular emphasis on section 83 of the Code; and the tax treatment of executive compensation in mergers, acquisitions and other corporate transactions. To the extent time permits, the course will also cover the rules relating to tax exempt organizations and foreign employers ( such as off shore hedge funds), including sections 457 and 457A.

  • Introduction to U.S. International Tax Policy (1 credit, TAX 901; Dana Trier)

    This course presents an overview of the policies that govern the approach of the U.S. government to international taxation. The course will begin with a description of the institutions in the U.S. government that formulate U.S. international tax policy, a brief summary of the U.S. international tax rules, and an overview of the U.S. Tax Treaty system and treaty policy. Then, the course will discuss pervasive policy concepts and problems such as the concepts of capital export, capital import and capital ownership neutrality; the problems of "tax competition," "stateless" income and international "tax arbitrage"; and the challenges of the digital economy. After these general concepts and problems have been discussed, the course will address in some depth transfer pricing, including the role of the arm's length method and its alternatives. Finally, the course will address several interrelated policy issues of current interest: the role of corporate tax rates in international tax policy; minimum taxes like the recently enacted GILTI rules and proposals for a global minimum tax; and the treatment of the interest deduction in the international context.

  • U.S. Tax Policy: Current Topics (2 credits, TAX 906)

    This course will discuss and analyze U.S. tax policy issues, with a special emphasis on recent tax developments, including the Biden administration’s tax proposals and the Tax Cuts and Jobs Act (most of which took effect in 2018).  The course will include discussion and analysis of the policy debates concerning capital gains rates, the corporate tax rate (as compared to tax rates for individuals and for activities conducted through partnerships), real estate investments (including section 1031 like-kind exchanges), tax benefits regarding principal residences, and the estate tax rules (as well as the basis of inherited property).  The course will also cover policy debates and issues relating to international tax, including the basic goals of U.S. international tax policy, taxation of intangibles, the relatively new GILTI regime, the concepts of capital import and export neutrality, the problem of income that escapes tax everywhere, hybridity and cross-border arbitrage, coordination between countries, and recent proposals for an international minimum tax on corporations.  (Note that the tax policy topics listed above may be modified to allow discussion of any new U.S. tax developments that occur during the semester.) 

  • Taxation of Athletes and Entertainers (1 credit, TAX 926; Patricia White)

    A case study, issue based practical introduction to tax issues and planning questions faced by professional athletes and entertainers. There will be several guest speakers. There will be no exam but there will be a final project and short weekly exercises.

  • New International Tax Consensus: OECD's "Pillar One" and "Pillar Two" Proposals ( 1 credit TAX 932; Andrew Solomon)

    The course description is as follows: In October 2021, the United States and 135 other countries, representing more than 94% of global GDP, agreed upon a so-called "Two-Pillar Solution” to address cross-border tax issues arising from the “digitalization” of the global economy. It is expected that, if and when implemented, the changes required by the agreement will fundamentally transform the international tax landscape. This course will consider the agreement that was reached and the changes that will be required (and have been proposed) in the United States to implement this agreement. TAX 916 International: Outbound is a corequisite for this course. Open to JD students with the permission of Tax LL.M. Director.

  • Tax Issues relating to Cryptocurrency and Blockchain (1 credit TAX 928; Rahul Ranadive)

    This course is an introduction to concepts and issues relating to the emerging cryptocurrency industry and the Federal tax policies evolving to provide a taxation framework. We will begin with a general examination of blockchain technology, its specific application to cryptocurrencies, and the wide range of various cryptocurrencies, utility tokens, equity tokens, stable coins and NFTs. This course will discuss and analyze U.S. tax policy issues, as well as how other federal and state agencies are regulating, licensing and taxing cryptocurrencies and cryptocurrency businesses with a special emphasis on recent developments. The course will focus on discussion and analysis of how traditional tax concepts concerning income tax, capital gains, corporate tax, and transfer tax rules are being adapted and applied to cryptocurrency activity. The course also will examine international tax issues, including how other countries are regulating and taxing cryptocurrencies. (Note that the tax policy topics listed above may be modified to allow discussion of any new U.S. tax developments that occur during the semester.)

  • Advanced Individual Tax Issues: Families and Lower Income Tax Payers (1 credit, TAX 907; Joseph Schimmel)

    This course will discuss many of the tax issues faced by “the other 98%” of individual U.S. taxpayers. We will address those provisions of the Code directed towards families and lower income taxpayers, including taxation of social security benefits, tip income, the tax treatment of “gig” workers, and other issues of the self-employed. We will discuss cancellation of indebtedness income (including COD in connection with bankruptcy). The course will cover filing status (including heads of households), dependents (the definition of a dependent, why it matters, and which taxpayer can use each dependent to impact the results under particular tax provisions), the earned income tax credit, child tax credit, and other personal credits (eg education credits). We will discuss the “marriage penalty,” the costs and benefits of being “married filing jointly,” and tax treatment of "married filing separately," as well as tax issues related to divorce. Open to JD students with the permission of Tax LL.M. Director.

  • Tax Issues Relating to Movement of Foreign Tech Founders into Miami in the 21st Century (1 credit, TAX 965; Andrew Whitaker)

    Miami over the past few years has grown exponentially as a tech hub due to a myriad of factors. Given the mobility of the industry, it provides the perfect case study for a cross-border course focusing on foreign individuals: foreign tech founders moving into Miami. The course will focus on the practical skills key to navigate tax planning when working with two differing sets of rules: U.S. and foreign tax laws. Three partner level tax practitioners (Brazil, Germany and to be determined) will join as the course works through the key US federal income tax considerations in planning for the movement of a foreign Tech Founder into the U.S. in a pre-liquidity scenario. The course will provide a synopsis of key US federal inbound and outbound tax rules, in conjunction with the practical skills necessary to identify key differences between U.S. and foreign tax law, including basic review of financial statements and how to model suggested planning. International: Inbound, Federal Wealth Transfer Tax, and Corporate Tax I/ Corporate Tax (or Taxation of Business Entities) are co-requisites. The pre-requisite and co-requisites may be waived by the instructor, eg based on previous coursework or work experience. JDs may enroll if they obtain the permission of the Director.

  • Tax Policy (1 credit, TAX 962; Rahul Ranadive)

    This course will discuss and analyze U.S. tax policy issues. The course will include discussion and analysis of the policy debates concerning capital gains rates, the corporate tax rate (as compared to tax rates for individuals and for activities conducted through partnerships), real estate investments (including section 1031 like-kind exchanges), tax benefits regarding principal residences, and the estate tax rules (as well as the basis of inherited property). The course will also cover policy debates and issues relating to international tax, including the basic goals of U.S. international tax policy, taxation of intangibles, the relatively new GILTI regime, the concepts of capital import and export neutrality, the problem of income that escapes tax everywhere, hybridity and cross-border arbitrage, coordination between countries, and recent proposals for an international minimum tax on corporations. (Note that the tax policy topics listed above may be modified to allow discussion of any new U.S. tax developments that occur during the semester.) Students will be required to write a paper. 3Ls may enroll if they obtain permission from the Director of the Tax LL.M. Program.

  • Tax Research and Writing (2 credits, TAX 963; Rebecca Rosenberg)

    This course will focus on “practice ready” skills of finding, interpreting, analyzing, and writing about the specialized materials that are unique to tax law. The course will examine how to progress from a tax law research question, through the research process, to a well-written, communicative memo for a supervisor or a client. Students will learn about various tax law sources of authority, such as cases (from the Tax Court and other courts); final, temporary, and proposed tax regulations and their preambles; IRS Rev Rules, Rev Procs, CCAs, TAMs, PLRs, Notices, and other issuances; legislative history; and Tax Treaties and their Technical Explanations. We will discuss the relative weight of authority of all of these sources, and how to use these various sources, in combination, to craft an argument. Students will also focus on how to communicate an analysis of these various sources of tax law in persuasive, professional writing. Students will complete short research assignments. The final course project will require students to research and write two tax law memos in response to the current year’s ABA Tax Section student writing competition. (Entering the competition is optional.) JDs may register if they obtain the permission of the Director of the Tax LLM program.