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. Course is 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. Course also focuses on the gathering and analyzing facts in the planning and drafting of trusts, wills, and related documents. 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.
Course includes income in respect of a decedent, tax consequences of trust beneficiaries, and tax problems of fiduciaries. Review of the net operating loss carryover and collapsible corporation rules. Maryland state and local taxation is emphasized. Students will also be introduced to the typical structure of oil and gas and other natural resource tax shelters. Detailed examination of the consolidated income tax regulations and consideration of other problems encountered by affiliated groups of corporations.