Curriculum Guide · Courses
Tax Shelters Seminar
Professors Blair & Pugh
LL.M Seminar 407 | 2 credit hours
The purpose of this seminar is to help students deepen their understanding of fundamental tax concepts applied in traditional tax planning by analyses of current tax motivated transactions ("tax shelters"). The course will consider, contrast and compare current tax shelters with seminal decided shelter and non shelter cases. Students will develop an understanding of and be asked to apply traditional tax concepts such as substance over form, step transaction, business purpose, economic substance, profit motive and rules of statutory construction. The course will include discussions of intended tax consequences, consistency with economics and risks, and assumptions underlying the income tax system. Policy issues, administrative considerations, the role of lawyer in the reality and sustainability of factual (including valuation) matters and ethical considerations will also be addressed.
[Prerequisite: Taxation I. Recommended: Prior enrollment in one or more of the following courses: Taxation II; Corporate Income Tax Law I.]