Seminar (cross-listed) | 2 credit hours. courses, Corporate Taxation (formerly Taxation II) or Corporate Tax Planning in Practice:Structuring and Negotiating the Deal. Recommended: Taxation of Charities and Other Nonprofit Organizations. On odd-numbered weeks, there will be a reading assignment consisting of one or two law review articles. Interested students should contact Ellis Duncan via email at ged5@law.georgetown.edu no later than November 15, 2020 for permission to take this class. International tax treaties determine why hedge funds are located where they are, how motion pictures are financed, whether the dispatch of employees abroad is economical, and why financial assets follow prescribed international paths. Enrolled students must be in attendance at the start of the first class session in order to remain enrolled. degree) pursuing the Taxation LL.M. By the end of the course, students are expected to understand how tax treaties are organized and be able to apply the model tax treaties to factual situations in which the tax treaties are applicable. LAW 2040 v00 Financial Derivatives Taxation. For example, it will analyze how federalist tensions and statutory dynamics were balanced in a proposed congressional bill concerning state and local tax incentives. The judgments delivered by the ECJ are most of the time very surprising, even to experts. After three introductory sessions, the workshop shifts to a series of weekly paper presentations by leading public finance economists, tax law scholars, and government experts. Annual tuition for the top programs -- a group that includes New York University School of Law, Georgetown … Being so pervasive, taxation is naturally an intensely political subject. This course will study current developments in US international tax policy, developments in multilateral international tax diplomacy, and the relationship between these two forces impacting US multinational tax planning. Browse discussion threads by topic below, … Students will learn the various international tax reporting obligations, applicable statutes of limitations and tolling provisions, potential civil penalties under the Internal Revenue Code and the Bank Secrecy Act, options for resolving non-compliance, procedures for challenging proposed and assessed penalties, and the risk of criminal investigation and prosecution. The course also presents and analyzes the drafting techniques necessary to actually implement such arrangements by concentrating on the tax and business provisions in term sheets and limited partnership/limited liability company agreements. Once registered, students will receive a password granting them access to TWEN. This course is an introduction to the law and policy of U.S. taxation of U.S. and foreign persons engaged in cross-border activities. To study the tax law, then, can be to examine the basic value choices that Americans have made. Accordingly, it covers subjects such as the time value of money, the distinction between debt and equity, the role of risk in valuing financial assets, and how assets and liabilities are described in accounting materials such as balance sheets and income statements. Note on Professional Licensure Major topics include the definition of income, deductions and exclusions, assignment of income, accounting, and issues of timing. Once registered, students will receive video account information for the course. The course begins by first introducing the student to the dynamics and taxonomy of SALT, and why (out of necessity) the study of subnational taxes must vary from the “classic” pedagogy of most LL.M. The principal focus will be on: (1) the tax structure utilized; (2) the tax representations, warranties, covenants, and indemnification provisions in the acquisition documents, along with any tax-sharing agreements; (3) the tax disclosure discussion in the proxy/prospectus delivered to the shareholders; and (4) the form of tax opinions provided by the buyer’s and the seller's tax counsel. Mutually Excluded Courses: Students may not receive credit for both this course and the J.D. LAW 844 v02 U.S. Legal Research Analysis & Writing (Tax Program). course Demystifying Finance. Note: This seminar requires a paper. Tax Filing Instructions Disclaimer IS Advisors are not tax specialists and cannot advise on tax matters or help complete tax forms. This course is open to J.D. This course seeks to provide an introduction to the United States' principals and current practice of international transfer pricing, as well as some understanding of the historical and conceptual basis of the current system. Prerequisite: Federal Income Tax and International Taxation (or U.S. International Inbound Tax and  U.S. International Outbound Tax). A course syllabus with topics covered and associated readings can be found here. Note: This zero-credit course is delivered via distance education to all students. It will include a historical review of Supreme Court jurisprudence that underscores the inherent complexities and tensions precipitated by the intersection of federalism and the underlying goals embodied within the Commerce Clause, Equal Protection Clause, Import-Export Clause, Privileges and Immunities Clause, and Supremacy Clause, among others. The decision is yours. The class will involve close reading of selected tax regulatory packages associated with the 2017 tax reform and major international tax policy documents published by the OECD. The class will also discuss the alternative income-based tax systems applicable to individuals: Individual AMT, Net Investment Income Tax, and Self-Employment Tax. The tax law has an enormous impact, pervading every sphere of public and even private life. This course will introduce students to indirect taxation, exemplified by the European Union’s Value Added Tax (“VAT”) and Canada’s Goods and Services Tax (“GST”), two of the fastest-growing indirect taxes globally. 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. and certificate programs (full-time, part-time and online) are open to applicants with either a J.D. 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