Course Descriptions

TAXA Course Descriptions

• TAXA 650 TAX RESEARCH AND WRITING (3)

  Covers research and writing projects on federal tax subjects with analysis and instruction in tax research techniques, materials and methodology. Students are required to prepare legal memoranda.

• TAXA 651 FUNDAMENTALS OF FEDERAL INCOME TAX I (3)

  Covers basic concepts in federal income taxation, including gross income, exclusions, adjusted gross income, deductions, exemptions, credits, assignment of income, identification of the taxpayer, tax rates, depreciation and the alternative minimum tax.

• TAXA 652 CORPORATE TAXATION (3)

  Covers federal income taxation of corporations and their shareholders with emphasis on the formation of the corporation, capital structure, operational alternatives, distributions, partial and complete liquidations, personal holding companies and the accumulated earnings tax. Formation, operation and liquidation of S corporations discussed briefly. Prerequisite: TAXA 651

• TAXA 653 PARTNERSHIP TAXATION (3)

  Explores problems encountered in the formation, operation and liquidation of a partnership, including the acquisition of partnership interests, compensation of the service partner, the treatment of partnership distributions and problems associated with the disposition of partnership interests or property by sale. Prerequisite: TAXA 651

• TAXA 654 TAX PRACTICE & PROCEDURE (3)

  Covers aspects of practice before the Internal Revenue Service, including ruling requests, handling of audits, assessment of deficiencies and penalties, closing agreements, tax liens, statutes of limitations, claims for refunds, appeals conferences and practice before the U.S. Tax Court, U.S. District Courts, Claims Court and appellate courts. Also includes analysis of the problems encountered in parallel civil and criminal proceedings, problems involving government investigatory powers and taxpayer rights and privileges. Prerequisite: TAXA 651

• TAXA 655 TAX POLICY (3)

  A study of the evolution and structure of the federal income tax system from a public-policy perspective with a focus on legal, economic, social and practical considerations. Alternatives, including current legislative proposals, are considered. Students prepare a paper on a tax policy issue approved by the professor. Prerequisite: TAXA 651

• TAXA 656 MARYLAND TAXES (3)

  This course will explore the substantive law and procedure of the Maryland taxes administered by the Maryland Comptroller, with a particular focus on Maryland income tax, corporate tax and sales and use tax. Other Maryland taxes administered by the Maryland Comptroller will be discussed briefly. In addition, this course will cover Maryland tax procedure, including how liabilities are calculated, types and methods of assessment, the dispute process, the state’s authority to collect and collection alternatives available. Prerequisite: Fundamentals of Federal Income Tax I.

• TAXA 658 INVESTIGATION, PROSECUTION, AND DEFENSE OF TAX CRIMES (3)

  This course examines the lifecycle of a criminal tax case, including the warning signs that a civil tax case may be referred for criminal investigation, applicable privileges, potential defenses, the opening of an administrative investigation, sources of information, authorization of a grand jury investigation and prosecution, best practices in plea negotiations, trial strategies, sentencing, and collateral and civil tax consequences. The course will also address current priorities of IRS Criminal Investigation and the Department of Justice, and cases pulled from the headlines. Prerequisite: Fundamental of Federal Income Tax I. Recommended: Tax Practice and Procedure

• TAXA 660 ESTATE AND GIFT TAXATION (3)

  Covers the basic principles of federal estate and gift taxation, including computation of the taxable estate, inter vivos transfers, transfers in contemplation of death, transfers with retained interests or powers, joint interests, life insurance proceeds, property subject to powers of appointment, the marital deduction and the unified credit. Prerequisite: TAXA 651

• TAXA 662 FOREIGN TAXATION (3)

  Analysis of the federal income tax provisions applying to U.S. inbound and outbound transactions and investments. Course covers U.S. resident status, source-of-income rules, graduated tax on effectively connected income, withholding tax on FDAP income, branch profits tax, FIRPTA, tax treaties, foreign tax credit, foreign earned income exclusion, Subpart F and transfer pricing. Prerequisite: TAXA 651

• TAXA 663 QUALIFIED PENSION AND PROFIT-SHARING PLANS (3)

  An introduction to pension and profit-sharing law with particular emphasis on Title 2 (IRS) of ERISA. Geared toward understanding all of the pension and profit-sharing rules that must be met for plan qualification, with emphasis on qualified plan planning for both incorporated and unincorporated forms of business. Prerequisite: TAXA 651

• TAXA 664 EXECUTIVE COMPENSATION (2)

  Covers methods of providing tax-free and tax-deferred compensation to employees, including section 83 tax planning, stock option tax planning, incentive compensation arrangements and methods of funding nonqualified plans. Prerequisite: TAXA 651

• TAXA 665 TAX EXEMPT ORGANIZATIONS (2)

  An analysis of provisions relating to the qualification for exemption from federal income tax, with emphasis on section 501(c)(3) organizations, private foundations and the treatment of unrelated business income. Prerequisite: TAXA 651

• TAXA 667 ESTATE PLANNING (972) (3)

  Examines methods of disposing of estates by will, life insurance, inter vivos arrangements and the consideration of resulting tax and administrative problems. Also focuses on gathering and analyzing facts in the planning and drafting of trusts, wills and related documents. additional prerequisite: TAXA 660

• TAXA 668 BUSINESS PLANNING WORKSHOP (3)

  An integrated study of the impact of tax, securities, corporate law and partnership law on business transactions. Topics include selection of the form of business enterprise, acquisitions and dispositions of business interests, and professional responsibility issues. Students prepare writing projects relating to the course material. additional prerequisites: TAXA 652 and TAXA 653

• TAXA 670 INCOME TAXATION OF ESTATES AND TRUSTS (3)

  Covers federal income taxation of decedents’ estates, simple and complex trusts, charitable trusts and grantor trusts. Also covers the preparation of fiduciary income tax returns with emphasis on unique tax issues such as income in respect of a decedent, distributable net income and fiduciary accounting. Prerequisite: TAXA 651

• TAXA 671 CORPORATE REORGANIZATIONS (3)

  Analysis of the tax treatment of corporations and shareholders in corporate acquisitions, divisions, reincorporations, and recapitalizations, including a discussion of section 338 and the net operating loss carryover rules. Prerequisites: Federal Income Tax and Corporate Taxation. This course is a combined J.D. and Graduate Tax Program offering. [Open Enrollment]

• TAXA 672 STATE AND LOCAL TAXATION (3)

  This course will explore federal and state constitutional and statutory limitations on state authority to tax individuals and business entities, including those that conduct multistate and multinational business. Featured topics will include the Due Process Clause and the Commerce Clause of the U.S. Constitution, taxation of individuals and business entities, sales and use tax nexus, and PL 86-272 limitations on state income taxation. In addition, the course will cover general sales and use tax (SUT) principles, apportionment of income derived from a multistate business, combined versus separate entity reporting, and state property taxes. Maryland's broad array of state and local taxes also will be examined briefly. Prerequisite: TAXA 651

• TAXA 674 CONSOLIDATED CORPORATIONS (2)

  An analysis of the techniques used by multiple, related corporations to report income and losses. Detailed examination of the consolidated income tax regulations and consideration of other problems encountered by affiliated groups of corporations. additional prerequisite: TAXA 652

• TAXA 675 ADVANCED REAL ESTATE TAXATION (2)

  An analysis of the effect of income taxes on real estate transactions; a comparison of the various entities used for the ownership and development of real estate; real estate syndications, basis and basis adjustments; alternative financing techniques such as the sale-leaseback; depreciation, amortization and obsolescence; passive activity and at-risk rules; and REITS. additional prerequisite: TAXA 678

• TAXA 676 FEDERAL TAX LEGISLATION WORKSHOP (3)

  A workshop course that examines the process of formulating and enacting federal tax legislation, as well as areas ripe for current federal tax legislative proposals; these areas may include income tax rates, capital gains taxation, tax expenditures, and the federal estate tax. Students will engage in drafting and other exercises that simulate the process of creating such legislation from the standpoint of staffers on Congressional committees. Prerequisite: TAXA 651 (Fundamental Federal Income Tax I)

• TAXA 678 FUNDAMENTALS OF FEDERAL INCOME TAX II (3)

  A continuation of basic tax concepts, including cash and accrual methods, capital gains and losses, 1231 transactions, recapture, original issue discount and imputed interest, below-market loans, installment sales, like-kind exchanges, involuntary conversions, at-risk rules and passive loss rules. Prerequisite: TAXA 651

• TAXA 679 WELFARE BENEFIT PLANS (2)

  Welfare benefit plans are employee-sponsored plans that provide employees with benefits other than pension and retirement plans and deferred compensation. Welfare benefit plans include life insurance, health insurance, disability insurance, vacation pay, severance pay, educational reimbursement, group legal services and dependent assistance care plans. This course focuses on federal income tax requirements for various welfare benefit plans, including fringe benefits and health-care continuation coverage under COBRA. Examines the income tax consequences to employers who sponsor, and employees who participate in, welfare plan benefits. Discusses the various mechanisms for offering welfare benefit plans, such as cafeteria plans under section 125 and VEBAs under section 501(c)(9). Prerequisite: TAXA 651

• TAXA 680 ADVANCED QUALIFIED PENSION AND PROFIT-SHARING PLANS (3)

  Building on the foundation provided by Qualified Pension and Profit-Sharing Plans, this in-depth examination of defined contribution and defined benefit plans includes current IRS positions; final, proposed and temporary regulations; and developing case law. Tax sheltered annuities are considered. additional prerequisite: TAXA 663

• TAXA 682 BANKRUPTCY TAXATION (2)

  An introduction to the basics of bankruptcy law and creditors’ rights and an analysis of tax issues that arise. Prerequisite: TAXA 651

• TAXA 684 S-CORPORATIONS (1)

  Covers federal income taxation of S corporations and their shareholders with emphasis on the creation of the S corporation, capital structure, operational alternatives, distributions and liquidations. Prerequisite: TAXA 651

• TAXA 685 ACCOUNTING FOR INCOME TAXES (2)

  An analysis of FASB ASC 740 Income Taxes. Such analysis will include the standards of financial accounting and reporting for income taxes that result from a company’s activities during the current and preceding year. The course will analyze income taxes that are currently payable under the respective income tax statutes as well as the tax consequences of those items that are deferred for federal income tax purposes but included for financial reporting purposes. Prerequisites: Fundamentals of Federal Income Tax I or Federal Income Taxation; Fundamentals of Federal Income Tax II

• TAXA 689 ADVANCED PARTNERSHIP TAXATION (3)

  This course builds upon the ideas presented in Partnership Taxation and provides students with additional skills that are valuable when practicing in the area of partnership taxation. Requires an ability and willingness to engage in critical thinking and problem-solving. Topics covered include the issues surrounding family limited partnerships; transferring property into and out of a partnership on a tax-deferred basis; recognizing transactions considered tax shelters or “abuses of subchapter K” under the current climate; and the international tax concepts. additional prerequisite: TAXA 653

• TAXA 690 STATE TAX POLICY ISSUES SEMINAR (2)

  This advanced state and local tax seminar consists of discussions of articles written by leading state tax theoreticians and practitioners regarding the present condition and likely future of state taxation in the 21th century. Each student will be expected to moderate at least one group discussion during the semester. The grade will be based on class participation and the completion of one publishable paper on a state tax policy topic of the student's choice, subject to the instructor's approval.

• TAXA 692 INTRODUCTION TO THE TAXATION OF FINANCIAL PRODUCTS (2)

  Study of the taxation of basic financial building blocks (equity, debt, options, notional principal contracts and forward contracts) and their various combinations. Financial equivalencies among traditional and derivative instruments that are taxed under widely varying tax regimes. Use of financial instruments to change the timing, character and source of income. Gaps in existing law, possible future tax regimes and emerging financial products.

• TAXA 780 BUSINESS VALUATION (3)

  Business valuation arises in mergers, acquisitions, divestitures, estate taxation, lost profits litigation, buy-out agreements, commercial lending, venture capital, IPOs, and other exit strategies. This course addresses valuation modeling, using asset pricing theory and practice and employing advanced applications such as data analytics applications and tools, and corporate databases. The course material is of interest to students who envision careers as CPAs, business valuation experts, corporate finance analysts and investment bankers. Prerequisite: FIN 605.

• TAXA 799 INDEPENDENT STUDY (1 - 2)

  Students may study an area of particular interest to them, not covered in a significant way elsewhere in the program, via an independent study. To qualify, students must submit a written proposal and obtain the consent of a faculty member who supervises the project. The proposal must be approved by both the supervising faculty member and the program director. Prerequisite: TAXA 651