Curriculum Guide · Courses
Cross-Border Tax Controversy Workshop
Professors Majure and Dicker
LL.M Skills 693 (cross-listed) | 3 credit hours
In this workshop course, students will work through hypothetical tax controversies involving cross-broader planning arrangements subject to examination in multiple tax jurisdictions. Students will be exposed to various arrangements which will serve as the basis for oral and written presentations as well as classroom discussion, and will analyze issues arising from transaction conception and implementation, U.S. and foreign enforcement, and potential avenues of multi-jurisdictional resolution. Students will assume key roles in these cross-border tax controversies, i.e., IRS exam team member on certain assigned issues and taxpayer on others, and will develop and pursue audit strategies accordingly. Written assignments will include drafting the principal documents associated with a tax controversy (e.g., hazards of litigation analyses, Information Document Requests and responses, IRS Notices of Proposed Adjustments, Appeals Protests, and settlement recommendations). Students will also participate in-class presentations, including mock "ex parte" and taxpayer appeals conferences.
Prerequisite: Taxation I.