Curriculum Guide · Courses

Professors Fleeman and Sieverding

LL.M Skills 809 | 2 credit hours

This is not an ordinary course in tax research and writing. We will cover basic tax research and writing skills -- but with an international focus. Even if you do not intend to specialize in international tax, it is increasingly likely that you will encounter cross-border issues during the course of your career. This will be true whether your clients are primarily corporations or individuals, pension plans or charitable organizations, or trusts or estates.

In the first half of the course, we will cover the basic concepts of tax research. We will begin with domestic materials, including statutes, legislative history, regulations, cases, administrative rulings, and secondary sources. Then we will cover tax treaties and other international materials, including other international agreements with tax provisions. We will discuss where these domestic and international materials can be located, the extent to which these materials are available electronically, and other practical aspects of researching tax issues in private practice and as an IRS attorney. We will also talk about the relative weight to be given to these various authorities and the interaction between domestic law and international agreements.

In the second half of the course, we will focus on developing effective writing skills. The ability to convey one’s thoughts accurately to a written work product is an essential skill in the legal profession. The strength of a legal argument depends not only on the sources of authority cited, but also on the manner in which those authorities are presented. There will be a brief legal research memorandum and a piece of persuasive writing on a current international tax issue that will provide you with a chance to use the research skills you learned in the first half of the course.

Prerequisite: Taxation I