Analysis of fundamental concepts of income taxation pertaining to individuals, partnerships, corporations, estates and trusts, exemptions and deductions.
Analyzes fundamental concepts of income taxation pertaining to sales and exchanges of property, including recognition and computation of gain or loss, amount realized, adjusted basis, installment or deferred payment method of reporting gain, private annuity transactions, common nontaxable exchanges, disallowed losses, treatment of capital gains or losses, capital asset qualifications, meaning of sales or exchange, holding period problems and special provisions concerning capital gains or losses.
Examines essential federal taxation issues for corporations, partnerships, estates and trusts. Topics include corporate organizations, operations, distributions, reorganizations and liquidations. S corporations and partnerships are examined and contrasted. Income and estate and gift taxation of estates and trusts are discussed.
s: This course covers the history and organization of the Internal Revenue Service and the Federal judiciary as it relates to tax controversies. Emphasis is place upon the examination and collection powers of the Service and the legal and technical responsibilities imposed upon representatives, with special emphasis place upon those imposed upon accountants. The deficiency and refund procedures are covered from the beginning of a tax controversy through its resolution by was of litigation. Included are the process by which returns are selected for examination, the conduct of examinations, the conduct of administrative conference proceedings, the Service’s investigatory and collection power, and those provisions available to taxpayers. The sources and nature of the Federal tax law and its legislative, administrative and judicial explanations and interpretations are covered. This course also introduces students to the research tools available to accountants, their uses and limitations, and the processes by which tax professional identify issues and apply controlling precedents in order to formulate research conclusions and professional recommendations.
History and organization of the Internal Revenue Service: selection of returns for audit; audit and conference procedure; preparation by accountant, attorney and corporate official for audits, hearings and conferences; government's investigatory powers, with special emphasis on the rights and responsibilities of accountants; restrictions on assessments; statute of limitations; statutory notices; rulings, determination letters and requests for technical advice.
Covers concepts and problems basic to different areas of taxation, such as the interrelationship of taxes, tax minimization principles, characteristics of taxable entities, the assignment or transfer of income, tax accounting principles and valuation problems.
Explains special tax considerations in compensating executive employees, in typical compensation devices and in the design of compensation packages in closely-held and publicly-held companies. Covers: short-term and long-term compensation arrangements (including stock options, restricted stock, stock appreciation rights and performance awards), retirement and health care plans designed to favor executives, tax-favored life insurance, low interest loans, fringe benefits, and corporate deduction considerations.
Covers various tax considerations involved in establishing, administering and terminating qualified pension, profit-sharing, stock bonus and related benefit programs from the point of view of the employer, the participant and his/her beneficiaries, the plan administrator and the plan fiduciary. Emphasizes the requirements for qualification, tax treatment of plan contributions and distributions, methods of investing and holding plan funds, tax exemption, prohibited transactions and fiduciary responsibility. Covers the interrelationship of tax and labor law provisions under ERISA (Employee Retirement Income Security Act of 1974).
Covers the various tax aspects of deferred compensation arrangements for executives and employees, other than tax qualified Pension and Profit Sharing plans. Emphasizes tax problems involved in unfunded deferred compensation arrangements, non-qualified trusts, annuities and other funded arrangements, employee death benefit programs, tax-sheltered annuity plans, IRAs and simplified employee pensions.
Covers tax considerations in establishing qualified and non-qualified deferred compensation arrangements from the point of view of the employer, the employee and his/her beneficiaries. Emphasizes the requirements for tax qualification, the treatment of plan contributions and distributions. Covers the interrelationship of tax and labor law provisions under ERISA.
Covers state and local tax problems, controversies and planning strategies of companies conducting business in multiple jurisdictions. Types of taxes discussed include income/franchise, gross receipts, license, and sales and use tax. Emphasizes tax problems associated with interstate and foreign commerce, audit issues and techniques employed in the major jurisdictions to minimize a company’s effective tax liability (such as separate accounting or combined reporting), and state and local tax developments throughout the country.
Introduces graduate tax students to U.S. tax law rules of international transactions and operations. Resident and non-resident alien status and consequences and inversions and expatriated entities are described. Discusses rules for determining the sources of income, allocation and apportionment of income, transfer pricing and the foreign tax credit.
Describes advanced concepts of U.S. and foreign tax law rules of international transactions and operations. Includes discussion of controlled foreign corporations, income effectively connected with U.S. business, tax withholding at source, FIRPTA, branch profits tax, section 367, foreign currency transactions and tax treaties.
s: Conducting foreign operations through U.S. entities: source of income rules; direct and indirect foreign tax credit rules; problems of allocation of income and deductions among related entities; treatment of foreign currency transactions; U.S taxation of U.S. citizens aboard; tax treaties, competent authority procedures and problems of double taxation; Conducting foreign operations through foreign entities: treatment controlled foreign corporations; Subpart F income and investment in U.S. property; Foreign Personal Holding Companies; U.S. taxation of aliens and foreign corporations with U.S. operations; discussion of foreign taxing jurisdictions.
Contrasts the difference between tax accounting and business accounting in the area of cash, accrual and installment reporting. It will also cover accounting periods, accounting methods, permissible changes and required adjustments in accounting methods, and inventory valuation.
An examination of the fundamental principles of estate and gift taxation, including taxable transfers, allowable deductions and credits, together with an analysis of the estate tax return and audit procedure and an introduction to planning techniques.
An intensive consideration of the techniques of estate planning through lifetime and testamentary transfers and the use of post-mortem options. Also considered are valuation problems, intra-family transfers, income in respect of decedent property, grantor trusts, charitable remainder and charitable lead trusts, private foundations and other income, estate and gift tax techniques available in the planning of estates.
Analyzes current real estate problems in light of legal, economic and governmental trends, including organization of partnership and corporate syndicates, dissolution and distributions of realty, or proceeds there from, sale and leaseback, installment and deferred payment sales, depreciation methods, limitations on the use of real estate losses, rehabilitation and low-income housing credits, and related issues.
Analyzes problems affecting organization and operations of partnerships; partners' withdrawals during lifetime, death or dissolution; sale or exchange or partnership interests; limited and family partnerships; and related estate tax problems.
Analyzes tax aspects of tax exempt organizations, including those of charitable and educational organizations, civic leagues, labor unions and health and welfare funds; general consideration in organizing tax exempt entities, including selection of appropriate form, such as corporation or trust; methods of obtaining and maintaining tax exemption; analysis of problems relating to feeder organization, prohibited transactions, unrelated business income, business leases, and rents and indebtedness; consideration of local and other types of taxation affecting tax exempt organizations, and tax consequences to distributees and related issues.
Taxation of income to fiduciaries, beneficiaries, grantors and other parties; income in respect of decedents; taxation of simple and complex trusts; computation of taxable net income and distributable net income; operation of the "throwback" rule; preparation of decedents; last return and returns of trusts and estates from inception through termination.
Considers the tax problems arising from investments in the securities (and allied) markets, such as wash sales, short sales, puts and calls, straddles, mutual fund and real estate investment trust shares, dealer versus investor trader, identification of securities sold, commodity futures, tax-exempt interest, arbitrage, and valuation.
Covers the rules governing the taxation of securities and financial instrument transactions entered into by individual and entities. The tax treatment of security, commodity and other financial instrument transactions are covered, with special emphasis placed upon transactions in stock, options, futures, foreign currencies and derivatives. The wash sale, straddle rules and other non-recognition rules are covered, as are the original issue and market discount rules.
: In-depth coverage of issues, emerging practices and problems facing tax professionals. Topics presented are at the department’s discretion and can vary from semester to semester. Representative topics include: tax law principles for consolidated tax return groups, tax legislative reform, and tax treatment of exempt organizations.
This Course will introduce students to the operation and taxation of the not-for-profit organization. It considers the policy questions associated with exempting organizations from liability for income taxes together with permitting donors to claim tax deductions for their contributions. Both tax-exempt organizations treated as public charities and those treated as private foundations will be studied. The applicability of the unrelated business income tax on both organizations is reviewed. The annual Form 990 tax return of the exempt organization is also examined. Finally, the various state level charitable solicitation reporting and disclosure laws are considered - with particular emphasis on the NYS Charities Bureau. If time permits, current developments will also be covered. Course Rotaion: NYC: Summer
Considers transfers on organizing a corporation, problems in corporate capitalization, dividend distributions, stock redemptions, partial liquidations, subchapter "S" corporations and the accumulated earning tax.
This course is a continuation of TAX 656 and covers corporate liquidations and collapsible corporations: domestic personal holding companies; multiple corporations.
Considers acquisitive and divisive corporate reorganizations; triangular reorganizations; carryover of tax attributes and limitations thereon; special attention is paid to tax and non-tax problems and their solutions.
Considers acquisitive and divisive corporate reorganizations; triangular reorganizations; liquidations; carryover of tax attributes and limitations thereon; special attention is paid to tax and non-tax problems and their solutions.
Considerations in determining whether an affiliated group of corporations should elect to file a consolidated income tax return; eligibility, computation of consolidated taxable income, liability for tax, effect on earnings and profits, corporations entering or leaving an affiliated group, sale of subsidiary's stock, deconsolidating.
Analyzes current developments in federal income, estate and gift taxation problems, including recent decisions, legislation, regulations and rulings.
Considers the role of ethics in tax practice and its application to specific tax problems. Explores the guidelines on tax practice as pronounced by the American Institute of Certified Public Accountants, the American Bar Association and the United States Treasury Department. Covers the ethical problems of tax practitioners in connection with tax planning, tax return preparation and representation before the Internal Revenue Service.
Explores the various current and future uses of microcomputers in the tax practice. Includes information processing, tax preparation and planning software, electronic tax research concepts and the use of electronic speadsheets as a tool in tax planning.
Studies the sources and nature of the Federal tax law and of its legislative, administrative and judicial explanations and interpretations, the research tools available and their uses and limitations. The research process employed to ascertain the state of the Federal tax law applicable to sets of facts and the formulation of research conclusions and professional recommendations are also explored.
Research project under the direction of the Instructor applying the principles studied in Research Methodology I.