Course Description

Core Classes

• 223A. Tax Research and Decision Making. Develops basics for tax research (including LEXIS-Computer Research) and evaluates the interrelationships of statutes,regulations, rulings and court cases. Identifies tax services and other primary research materials with emphasis on their use in tax decision making. Prerequisite: Graduate standing.




• 223B. Taxation of Partnerships. Income tax treatment of partners and partnerships including their creation, operation, liquidation and sale or other amalgamation. Special allocation and non-recourse debt arrangements are covered also.
  Prerequisites: Bus. 223A and graduate standing.




• 223C. Taxation of Corporations and Shareholders. Income tax treatment of transactions involving creation of the corporation entity. Operations including AMT and ALE, liquidations and stock redemption's, tax treatment for both the corporation and
  shareholder, taxation of dividends and other distributions. Taxation of personal holding companies and accumulated profits. Prerequisites: Bus. 223A (or concurrently) and graduate standing. 3 Units




• 223D. Seminar in Tax Planning & Practice. Capstone course for the MS in Taxation degree. Will integrate concepts covered throughout the program. Includes comprehensive project. (Completion of this course or Bus. 223E satisfies the MST
  comprehensive project/capstone requirement.)
  Prerequisite: Completion of Bus 223A, 223B, 223C and 223F.




• 223E. Business & Tax Aspects of High Technology Companies. This course will cover tax in business issues facing high technology companies including stock options, R&D, package design, fiscal and public policy issues, multistage financing,joint venturing, Section 482, Section 382, going public, etc. Includes comprehensive project. (Completion of this course or Bus. 223D satisfies the MST comprehensive project/capstone requirement.) 
  Prerequisite: Completion of Bus 223A, 223B, 223C and 223F.




• 223F. Tax Accounting Methods/Periods. Definition and requirements of alternative accounting methods, including IRS requirements to change from one method or period to another; special methods and inventory valuation and reserve problems; software and R&D tax accounting rules.
  Prerequisite: Bus. 223A. 3 units.

Course Descriptions: Electives

• 225A. Taxation of Estates and Trusts. Income and transfer tax treatment of estates, gifts, trusts creators, beneficiaries, and fiduciaries. Distinguishes between simple and complex trusts, including proper trusts to achieve desired goals. Reviews taxation of asset sales and dissolution or liquidation of estates or trusts as well as AMT implications. Analyzes estate planning and valuation opportunities.




• 225B. Taxation of Corporate Reorganizations. Income tax treatment of corporate reorganizations and amalgamations including acquisitions, tax-free and taxable as well as corporate divisions. Course covers tax treatment of net operating losses, earnings and profits, property basis, and other corporate attributes.




• 225C. Taxation of International Transactions I. Taxation of offshore US citizens, resident and non-resident aliens, foreign corporations and other business organizations and U.S. foreign-owned real estate. Tax effect of source rules and foreign
  tax credits (including limitations). Taxation of U.S. controlled foreign corporations(Subpart F).
  Prerequisite: Bus. 223A and Bus. 223C. 3 units.




• 225D. Taxation of International Transactions II. Taxation of inter-company transactions of U.S.-controlled international business groups, including transfer pricing and tax effects of adjustments made by the IRS. Taxation of international financing subsidiaries and special organizations, i.e., possessions corporations (Puerto Rico) and FSC. Reviews international business structures from tax perspectives.
  Prerequisite: 223A, 223C, 225C, and 223D.




• 225F. State and Local Income Taxation. Application of interstate income allocations, multi-state tax impact, separate versus apportionment concepts, foreign country source rules, and unitary tax. Also California taxes as sales tax on technology transfers.




• 225G. Taxation of S Corporations. Income tax treatment of S corporations and their shareholders, including the built-in gains tax and excess net passive income tax. Operating and distribution rules, shareholders basis, and NOL pass-through rules will be discussed in detail. Formation, reorganizations, and state income tax consequences will also be discussed.




• 225H. Taxation of Property Transactions. Tax aspects of property transactions, including real estate, intangibles, and tangible property. Corn Products, Arkansas Best, and Arrowsmith court doctrines will be covered. Passive activity losses, like kind exchanges, and involuntary conversions will be presented; as well as patents franchises, etc.




• 225I. Tax Practice, Penalties, and Procedure. Federal and California aspects of prepare/valuation penalty provisions, 30-day and 90-day letter issues, power of attorney, professional ethics, malpractice and criminal penalties and provisions

• 225J. Taxation of Executive Compensation. Tax aspects of executive compensation including qualified and nonqualified stock options, deferred compensation, fringe benefits, 401(K); 403(B), pension and profit sharing plans, rabbi trusts, etc.

• 225K. Advanced Individual Taxes. Interest tracing, passive activity losses,net operating losses, AMT's impact on individuals and individual California income taxes.




• 225L. Accounting for Income Taxes. This course will cover the interplay of income taxes and financial accounting, including deferred income taxes under APB #11 and FAS #96, with both regular tax and AMT being reflected. It will also cover post-benefit
  retirement, permanent investment overseas, stock options, and &D and software accounting.




• 225M. State & Local E-Commerce, Sales, Use and Property Taxes.To develop an understanding of Nexus and the structure and application of sales and use taxes. especially California,  The course will cover as variety of specific transactions such as technology transfers, leases, manufacturing equipment, mergers and acquisitions,and the procedural rules for audits, appeals and claims.  It will also develop a general understanding of the property tax rules, the rules on changes of ownership of real property and U.S. custom taxes.




• 225N. Going Public +/- 1 Year.Business, legal, and tax aspects of preparing a company to go public and subsequent events; including switching S to C, 382, 162 (m), options, players in the process, SEC rules and filling requirements.




• 225O. Taxation of Tax Exempt Organizations.Taxation of tax exempt organization, including application of UBIT: investment in partnerships and S Corp., foundation, pension plans, VEBAS, form 990's.