The topics that we will cover include comprehensive income taxation, the rate structure, personal deductions, income versus consumption taxation, and tax expenditures. students may take the seminar pass/fail by professor permission only. 2) Performing a transfer pricing analysis for a particular multinational group, and assisting the group in implementation. Please note that there are unique applications for those applicants who received their first degree in law in the United States (i.e. course Corporate Transactions, or the J.D. View Meggie Chen, Esq., PhD, JD, LLM’S profile on LinkedIn, the world’s largest professional community. CSJTax. Note: This class will require a final paper and a short mid-term paper. degree or the Taxation LL.M. This course provides students with an opportunity to consider and address the ethical issues that attorneys frequently encounter in different kinds of modern-day tax practice, either tax planning or controversy. The student completing this course will have a basic understanding of how to approach foreign tax law, and tools to better understand the tax system in the student’s own country. Major topics include the fiscal and social purposes of taxation, the choice of tax base (including alternatives to the use of income as the tax base), the identity of the taxpayer, timing issues (including realization issues and deferral), territorial versus worldwide taxation (including source rules and cross-border transactions), and administrative issues (including the legislative process, tax enforcement, and tax ethics). The required courses cover the four … Withdrawals are permitted up until the last class for this specific course. This seminar will set out the background to these debates and provide a greater context to these taxes, introducing students to debates within the United States about sales taxes and debates both inside and outside the United States about the future of the international tax system. LAW 3017 v00 Survey of Employee Benefits Law. Upperclass Legal Writing Requirement. Prerequisite: Federal Income Taxation (formerly Taxation I), Decedents’ Estates or equivalent, or concurrent enrollment in Wills & Trusts; Income Taxation of Trusts, Estates, and Beneficiaries; Estate and Gift Tax. graduate from Georgetown University Law Centre, where she completed the Taxation … It will cover fundamental tax treaty concepts such as residency, permanent establishment, business profits, limitation on benefits, and relief from double taxation (including operation of the U.S. foreign tax credit rules). The consequences of filing consolidated returns in specific situations are considered as each topic is covered. Most legislative measures of the European Union in this area require the consensus of all 27 member states. Also considered are IRS summons enforcement litigation, civil collection, levy and distraint, and the tax lien and its priorities. The Corporate Taxation Certificate requires the following core courses: 1. This course will cover the basics and the finer points of the foreign tax credit, an important issue for virtually all multinational taxpayers. Please review our … It will explore the economic and policy literature surrounding the issues of economic welfare and competitiveness. Waitlisted students must be in attendance at the start of the first class session in order to remain eligible to be admitted off the waitlist. Constitutional limitations applicable to Sales & Use taxes and state efforts to bypass these limitations to tax remote sellers. Georgetown Law is a member of the State Authorization Reciprocity Agreement (SARA), which allows online programs that demonstrate compliance with their home state's authorization requirements to enjoy reciprocal authorization in all other SARA states, which include D.C., Puerto Rico, and all U.S. states except California. Absent a true family or medical emergency, you will receive a failing grade on any paper not submitted by that deadline. options with our comprehensive database of programs in the United States. 4. Mutually Excluded Courses: Students who take this course may not enroll in U.S. International Inbound Tax (formerly: U.S. This course will cover the basic concepts of tax research and tax-specific writing techniques and skills. We will cover legislative, administrative, judicial, and secondary sources of authority. Please tell your recommenders that they may submit their letter in any of the following ways: •Mail original letter to the Office of Admissions in a sealed/ signed envelope (must come directly from recommender), Graduate Admissions LAW 765 v00 Federal Taxation of Bankruptcy and Workouts. Recommended: Prior or concurrent enrollment in Corporate Income Tax Law II (or completion of Corporate Taxation (formerly Taxation II)). in Taxation or other tax certificate program must sit for a 90-minute, 50-question multiple choice exam at the conclusion of the course and achieve a passing score of 30 out of 50 questions.  The final exam will be administered on the TWEN webpage for the course. LAW 947 v00 Special Topics in Exempt Organizations. It covers the recently enacted GILTI rules, the Foreign Tax Credit provisions, Subpart F, repatriation, section 367,  foreign currency considerations, Passive Foreign Investment Companies, and overall strategic tax planning, including the significant new U.S. international tax rules and other changes introduced by the 2017 Tax Cuts and Jobs Act. In challenging the conventional story of the right of publicity’s emergence, development, and justifications, Rothman shows how it transformed people into intellectual property, leading to a bizarre world in which you can lose ownership ... Your score should exceed 100 points on the internet-based TOEFL exam (with minimum scores of 25 in each of the four sections) or 600 on the paper-based TOEFL exam (with minimum scores of 60 in each of the three sections). Credits may not be double-counted towards both an LLM and a certificate. seminar, Current Issues in Tax Law and Policy Seminar or the graduate seminars, Tax Policy or Graduate Seminar: Federal Tax Policy. The ERISA discussion will focus on plan design, reporting and disclosure, claims procedures, and fiduciary duty rules. Our full-time faculty includes teachers and scholars who are regularly consulted by business, the United States government, and international organizations, including the International Monetary Fund, the OECD and the World Bank. degree or the Taxation LL.M. Mutually Excluded Courses: Students may not receive credit for both this course and the graduate courses, Corporate Income Tax Law I or Corporate Income Tax Law II. If you are an internationally-educated student, we strongly encourage you to register for LSAC's International Transcript Authentication and Evaluation Service (additional charge). This course will cover the basics and the finer points of the foreign tax credit, an important issue for virtually all multinational taxpayers. 24 … The course concludes with study of current international enforcement and litigation trends involving cross-border business transactions and base erosion/profit shifting issues. The introductory course in transfer pricing is recommended, but not required. Georgetown University Law Center Mutually Excluded Courses: Survey of Employee Benefits Law. The only real engine of harmonization seems to be the European Court of Justice (ECJ). The Certificate is open to both U.S. and foreign-trained lawyers, as well as non-attorney tax professionals, and can be completed together with the Tax LL.M. This is a basic tax treaty course. The strength of a legal argument depends not only on the sources of authority cited but also on the manner in which those authorities are presented. Students will practice the research and writing skills developed in class by drafting a piece of tax-related writing throughout the course of the semester, receiving feedback and editing the draft along the way. Juris Doctor) and those that received their first degree in law from another country. This course is designed to provide an introduction to the U.S. income tax for foreign graduate students. The second module will consist of a hands-on exercise in developing, drafting, and executing a complex estate plan. degree or on a stand-alone basis. Examines in-depth the provisions of Subchapter K of the Internal Revenue Code and the regulations thereunder. You may, if you wish, try to summarize the argument (not as easy as it may seem). The class will be divided into separate "law firms" of 4 or so students per firm. A course in tax practice and procedure is recommended but not required. August 2021 Canvas Changes and Updates. Prerequisite: Federal Income Taxation (formerly Taxation I); Corporate Income Tax Law I. Note: This class, Income Tax Accounting, is required for U.S. trained students pursuing the Taxation LL.M. This course studies the law and regulations governing the taxation of corporations filing consolidated federal income tax returns. Each office has a unique website with program … LAW 670 v13 Recent Tax Legislative Developments. Georgetown tax llm tuition free versus NYU tax llm at $22,000 for tuition. My email address is: (sbclawprof@aol.com). The course will also consider how the U.S. rules in these areas are influenced by developments in other countries. The LLM Tax curriculum gives students a foundational understanding of tax law, which they can apply to a wide array of specialty tax elective courses. Students will learn the rules that govern who is entitled to a credit; for what taxes a credit may be claimed; and how large a credit may be taken; and in what year the credit properly accrues. – Tax programs that have come to focus and build on a study of the differing subchapters of the Internal Revenue Code.  Next, the course explores important subnational topics not encountered in the study of federal corporate income taxes, such as federal limitations on the powers of subnational governments to tax.  To close the course, the student will be presented with a case study and a comparative law analysis that will provide them insight into analytical approaches employed by interdisciplinary tax teams made-up of international, federal and subnational tax specialists assigned to deal with enterprise restructurings. Beginning with the gift tax, topics covered will include what constitutes a taxable gift, what types of property transfers are not gifts, and when a gift is treated as complete for Federal gift tax purposes. Note: The course will include occasional presentations by guest speakers experienced in the field of international tax. The course will cover the tax consequences of outbound transfers of assets, foreign-to-foreign transfers of assets, and inbound transfers of assets. Each week's hypothetical case study will consist of a fact pattern, including financial and operational data, presenting a set of business objectives and/or problems to resolve. With telecommuting, internet and other work options, and a fluid workforce, this course will also review the state and local tax rules for employers/employees and individuals. They determine whether bank accounts in Switzerland and Liechtenstein are really secret. 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