Tax Policy Seminar (D. Gam*ge)

This seminar explores the policy foundations of the federal system for taxing income. We will engage with a number of traditional tax policy debates, including: concepts of income and the tax base; the goals of equity and efficiency; the tax expenditure concept; the double taxation of corporate income; and the alternative of consumption taxation. Additionally, we will devote several class sessions to discussing the tax legislative process and interactions between tax and budget policy. Although not a strict prerequisite, it is recommended that students take Federal Income Taxation before enrolling in this course.

Corporate Income Tax (E. Rak*wski)

This course covers the federal income taxation of corporations. It follows the tax life of a corporation, from its formation, to its distribution of cash or property to shareholders, to its eventual liquidation. It also covers the tax aspects of corporate mergers, acquisitions, and divisions, such as the spin-off of a corporate subsidiary. Although most of the emphasis is on large, publicly traded, Subchapter C corporations, the course covers the contrasting tax treatment of smaller, Subchapter S corporations as well. The course does not require any mathematical expertise and is designed for those considering general or corporate practice as well as for studetns with a special interest in tax law.

Partnership Tax (A. DeL*o)

Entities that are treated as "partnerships" for income tax purposes - general partnerships, limited partnerships, limited liability companies - are everywhere in today's business world: from real estate ventures to private equity and hedge funds to venture capital start-ups. This course will cover the Federal income tax treatment of partners (including members in LLC's) and partnerships (including the taxation of limited liability companies and other entities treated as partnerships for income tax purposes). Topics to be covered include: (i) what is a partnership? (ii) the entity theory versus the aggregate theory of partnership taxation; (iii) the capitalization of the partnership, including contributions of appreciated or depreciated property; (iv) the grant of a partnership interest for past and/or future services; (v) the treatment of "promotes" and "carried interests"; (vi) the taxation of ongoing partnership operations; (vii) partnership distributions; (viii) partnership allocations and "substantial economic effect"; (ix) inside and outside basis determinations, and the treatment of liabilities under section 752; (x) partnership liquidations; (xi) transfers of partnership interests; (xii) "hot" assets; (xiii) partnership terminations; (xiv) section 754 and other special basis elections. This course may be taken during the same semester as Corporate Tax.