Prerequisite: L6256 Federal Income Taxation
Evaluation by Take-Home Examination
Writing Credit by Request
The course will provide an introduction to the taxation of partnerships and limited liability companies. The course will concentrate on the basic principles applicable to formation of partnerships; the determination of partnership income and loss and its allocation among the partners; the treatment of sales and exchanges of partnership interests and distributions of money and property from partnerships. The course will provide an understanding of the fundamental technical statutory and regulatory rules. In connection with the development of these skills both the lectures and class room discussion will include an examination of tax policy issues and how resolution of those issues help to explain and support the technical rules.
During the course, students will be asked to consider the role and ethical responsibility of the tax professional in advising clients. These issues will generally be presented in evaluation of cases and tax shelters which highlight the tension between the use of partnerships as a tax planning devise and the need to curb potential abuses. Attention will also be given to current legislative reform efforts dealing with partnerships generally and alternative investment vehicles, such as hedge funds and private equity funds, in particular.
Class work and assignments will focus on problems (distributed each week and discussed in class) which illustrate the statutory and regulatory provisions. Because the course relies on a basic familiarity with income tax principles and terminology, Federal Income Taxation is generally a prerequisite, although students with prior experience in taxations (LLM candidates and those with accounting experience) should consult with me about waiver of the prerequisite..