This course examines the federal income tax treatment of partnerships and partners. Students study partnership formation, problems of partnership operation including distributions, sales and exchanges of partnership interests, partnership terminations and liquidations, special basis adjustments and the role of partnership as investment vehicles. The treatment of limited liability companies and limited liability partnerships are also examined. Students will be required to prepare a Form 1065. This course is a study of federal tax practice and procedure.
Tax fraud is considered briefly.
This course provides a detailed examination of the law dealing with criminal tax fraud and other tax crimes. Students study direct and indirect methods of proof, administrative procedures and attitudes, privileges and protections under the U.S. Constitution, use of the Freedom of Information Act, and the role of accountants in criminal tax fraud cases. The application of the Internal Revenue Code to domestic corporations doing business in foreign counties either through subsidiaries or as branch operations. Intercompany pricing will be considered in detail. Also covered are tax treaties, FSC s, foreign currency, and the US tax treatment of foreign persons and foreign businesses engaged in US activity.