Specific issues of operating in corporate form, including corporate reorganizations and divisions, carryovers of tax attributes, and limitations on carryovers. The interplay between U.S. and international tax, legal, and business considerations in formulating an overall tax-efficient global strategy. The special tax rules applicable to bankruptcies, including taxation of individual bankruptcy estates, G reorganizations, net operating losses, relief of indebtedness income rules, and federal tax claims. An introduction to federal wealth transfer tax, including estate, gift, and generation-skipping transfer taxes. A study of various estate planning topics such as the unified credit, marital deductions, charitable deductions, generation-skipping transfers, life insurance, trusts and their uses, and family limited partnerships.
Emphasis is on practical skills needed to create a uniform estate plan.
Nonqualified retirement plans including stock option plans, top hat plans, excess benefit plans, and related issues. An initial overview of federal income taxation of individual taxpayers, including concepts of gross income, adjusted gross income, taxable income, deductions, exemptions, and credits. It is too basic for most LL.M. students. However, if you did not have a tax course in your J.D. curriculum, if you attended a foreign law school, if you graduated from law school several years ago, or if you otherwise feel the need for a J.D.-level review, you may take this course and receive LL.M. credit. The LL.M. and J.D. calendars are not always congruous.