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Course Criteria
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3.00 Credits
Examines issues related to the allocation of items of income and deduction to the proper taxable year, including adoption of tax year end; definition of method of accounting; the annual accounting concept; cash, accrual and installment methods of accounting; time value of money; and the Uniform Capitalization Rules. Co-requisites TA 318 and TA 329.
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3.00 Credits
Analyzes taxation of trusts and estates and their creators, beneficiaries and fiduciaries, including computation of distributable net income and taxable net income, taxation of simple and complex trusts, operation of "throwback" rules, computation of income in respect of a decedent,preparation of the last return for a decedent and the returns of trusts and estates from inception through termination. Prerequisites: TA 318 and TA 329.
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3.00 Credits
Examines the application of the sales, use, B and O and real estate excise taxes in specific industries and transactions. We will give special attention to the local business doing all or a portion of its business in other states and the accountability of out-of-state business for collecting Washington state taxes, including apportionment formulae and recent developments. We will also cover audits, appeals and negotiations with the Department of Revenue.
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3.00 Credits
Surveys the different types of employment taxes, including analysis of common and statutory law related to employees versus independent contractors status including "household help" issues. You will learnproactive tools related to re-characterization and post assessment issues and how to contest a worker re-characterization. Prerequisites: TA 318 and TA 329.
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3.00 Credits
Analyzes constitutional, federal and state limitations on taxation, persons and transactions subject to tax, exemptions, basis of tax, compliance requirement and appeals and procedures. Emphasis placed on taxation of transfers of technology including computer programs and research-and-development contracts; manufacturers, graphic arts and related enterprises, businesses engaged in retailing and transactions in interstate and foreign commerce. Case studies used to illustrate concepts. Prerequisites: TA 318 and TA 329.
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3.00 Credits
Presents an analysis of choice of entity for family businesses and wealth succession, including buy-sell agreements, compensation planning and equitable allocation of wealth among heirs. Prerequisites: TA 325 and TA 334.
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3.00 Credits
Examines business and investment transactions by nonresident alien individuals and foreign corporations earning income in the US ("inbound transaction") including: residence for income taxation,sources of income, sources and allocation of deductions, US taxation of passive income by nonresident aliens and foreign corporations, the branch profit tax and gains of foreign taxpayers from the sale of US Real Property. Prerequisite: TA 321.
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3.00 Credits
Covers US taxation of foreign operations by US individuals and corporations including an in-depth analysis of the foreign tax credit, controlled foreign corporations, passive foreign investment companies, foreign sales corporations, and foreign currency transactions. Prerequisite: TA 321.
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3.00 Credits
Provides an in-depth coverage of inter-company pricing rules, including inter-company sales, loans, services, leasing, and transfers of intangibles. The following will be discussed: inter-company sales cases, as well as the treatment of inter-company loans under the imputed interest and below market loan provisions. There will be an examination of advance pricing agreements and relevant treaty provisions. Prerequisite: TA 321.
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3.00 Credits
Analyzes the US tax issues relating to both inbound and outbound mergers, acquisitions, and joint ventures, including taxable acquisitions and dispositions, joint ventures, tax-free acquisitive exchanges and reorganizations, and distributions and divisive reorganizations. Prerequisites: TA 350A and TA 350B.
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