Curriculum Guide · Courses

Professor Thomas Field

LL.M Seminar 441 (cross-listed) | 2 credit hours

This course will equip students with the tools they need to think about fundamental tax policy issues. It will illustrate those issues by reference to tax policy questions that the U.S. Congress, Treasury Department, and Internal Revenue Service have recently considered.

The course focuses primarily on Federal corporate and individual income taxes. However, other Federal taxes, including employment taxes and estate and gift taxes, will also be considered. In addition, state and international tax practices will be discussed when relevant.

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).

All students must provide five-minute pre- and post-class responses for each class via the TWEN database, and must participate actively in class discussion. Students in this course will be expected to write a 15- to 20-page research paper.

Prerequisite: Taxation I.

Students may not receive credit for both this seminar and the J.D. Seminar, Current Issues in Tax Law and Policy Seminar, or the J.D. Seminar, Tax Policy Seminar.

LL.M. students are presumed to have taken the prerequisite of Taxation I prior to entering their program of study. Interested J.D. students must have completed Taxation I prior to this course.