Curriculum Guide · Courses
Tax Penalties and International Enforcement (formerly: Tax Penalties and Tax Crimes)
Professors Greaves and Marshall
LL.M Course 857 (cross-listed) | 2 credit hours
Tax penalties are asserted in almost every tax controversy. This course will teach you about the tax penalties that transactional and controversy practitioners must regularly consider. After exploring the traditional civil tax penalties, we will consider penalties and enforcement in the international arena. With legislative and enforcement focus on international issues in recent years, we will discuss both traditional approaches and cutting-edge issues. Finally, we will explore the bridge from civil to criminal tax. Students will examine relevant statutes, regulations and case law. We anticipate a few guest speakers from law firms, IRS and/or the United States Tax Court.
Prerequisite: Interested J.D. students must have taken Taxation I prior to this course; all LL.M.s are assumed to have taken Taxation I or its equivalent as a prerequisite to the program.