Taxation

Corporate Tax

Lecture - 3 hours. This course is an examination of the federal income tax relationship between corporations and their owners. The class will cover the transfer of funds into a corporation on formation and the re-transfer of money and property from the corporation to its shareholders. The course also considers taxable and non-taxable corporate restructuring in the form of sales, mergers, acquisitions, and divisions of corporations. 

Prerequisite: Law 220 Federal Income Taxation
Final Assessment: Exam

Tax Issues Related to Estate Planning

Discussion - 2 hours. Recommended: 221 Trusts, Wills, and Decedents' Estates. Fundamentals of federal transfer taxation, including the estate tax, the gift tax, and the generation-skipping transfer tax.

Please note: students who have already taken Estate and Gift Taxation are not eligible to take this course.

Prerequisite: 220 Federal Income Taxation.

Federal Income Taxation

Discussion - 4 hours. There are no prerequisites, although this course is a prerequisite for most other tax courses. This course surveys the federal income tax system, with consideration of the nature of income, when and to whom income is taxable, exclusions from the tax base, deductions and credits, and tax consequences of property ownership and disposition. Our objective will be to explore and critically evaluate the concepts and policies underlying the federal income tax, as well as to learn to interpret the statutory provisions by which these concepts and policies are implemented.

State and Federal Tax Externship

All King Hall externships have two components. Students perform substantive legal work at a field placement, and under the supervision of a faculty advisor, complete professional development assignments. Each externship class has a syllabus outlining those requirements. See the Externship website for more information. Student externs work with the Internal Revenue Service or other governmental tax agency, such as the California Franchise Tax Board and the California Office of Tax Appeals.

Nonprofit Organizations and Drafting: A-Z Coverage with Document Drafting

Discussion plus document drafting skills - 4 hours. This course is a combination skills class and a lecture course.  Students learn the special legal rules and concepts applicable to nonprofit organizations (particularly IRC 501(c)(3) nonprofits) and then, in a workshop class structure, they apply those rules and concepts to complete drafting assignments regarding the formation of nonprofit organizations under state law and the application for tax-exempt status for nonprofit organizations under Federal tax laws.

Taxation of Partnerships and LLCs

Discussion - 3 hours. A great number of businesses utilize the partnership structure, including closely-held operating businesses, most investment entities, including private equity, venture capital, real estate and hedge funds, and publicly-traded master limited partnerships.  This course constitutes a study of the federal income tax treatment of partnerships and partners (including entities classified as partnerships).

Trusts, Wills, and Estates

Discussion - 2 hours.  This streamlined version of Trusts, Wills, and Estates is designed for students who are mainly interested in taking the course to prepare for the bar exam. It covers the basics of intestate succession and the creation and interpretation of wills and trusts under the Uniform Probate Code and the California Probate Code. Although it does not delve deeply into these issues, it sets the stage for students to master them during the bar review period.  

International Taxation

Discussion - 3 hours. This course will introduce students to the international aspects of taxation and how the regime bears on broader social debates. This includes how U.S. tax law generally treats "foreign" income, as well as contemporary and evolving controversies, including how recent federal tax reforms treat global intangible low-taxed income (GILTI).

Core course for Tax Law Certificate Program.

Pre-requisites: Law 220 Federal income taxation is highly recommended though not required.

Tax and Distributive Justice

Discussion - 3 hours. This is an advanced tax course designed to introduce students to issues of tax policy, with particular emphasis on tax distribution (i.e., who or what should pay taxes in society) and tax incidence (i.e., who or what ends up paying taxes in society). The course will begin by examining official measurements of income and wealth distribution, as well as how those measurements comport with the philosophical foundations of various conceptions of justice in taxation, including libertarianism, utilitarianism, and liberal egalitarianism.