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Course Criteria
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3.00 Credits
Description: Prerequisites: Taxation of Corporations and Shareholders, International I (strongly recommended but not essential) This is the outbound course of the US taxation of non-US operations of US persons. Topics covered include the denial of deferral of income under Subpart F, the availability and limitations on the foreign tax credit, the disposal of controlled foreign corporations, foreign currency issues, an introduction to transfer pricing, and the impact of tax treaties. (This course replaces U.S. Taxation of Foreign Persons.) 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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3.00 Credits
Description: Prerequisites: Taxation of Corporations and Shareholders Detailed examination of the consolidated income tax return regulations and consideration of other problems encountered by affiliated groups of corporations. 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: Legal and practical problems arising when criminal prosecution is or may be contemplated. Government investigatory powers and taxpayer rights and privileges. Extent of civil and criminal penalty provisions and of permissible limits of tax avoidance. 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: An examination of the Code provisions related to qualification for exemption from federal income tax, with special attention to the 501(c)(3) exemption, private foundations, treatment of unrelated business income, and charitable contributions. 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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3.00 Credits
Description: Prerequisite: Taxation of Corporations and Shareholders This is an inbound/tax treaty course which is the first building block. The course focuses on the US taxation of non-US persons, both under the Code and applicable tax treaties. We will analyze the statutory framework, and pay particular attention to the question of when activities or nexus with the US is sufficient for the US to assert taxing jurisdiction. For example, when is a non-US investor buying securities as compared to being in the lending business in the US Can a BVI (British Virgin Islands) company sell goods into the US without US tax Attention is then paid to investment type income that is not connected with a US business -interest, dividends, royalties, rents, investment in US real property, etc. Lastly, the mechanics of collecting the tax will be reviewed. --- (This course replaces U.S. Taxation of International Business Operations.) 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: Analysis of transactions affecting real estate, including advanced issues in real estate depreciation, repairs and capitalization, real estate taxes, easements and severance damages, workout structuring and mortgage foreclosure, leases and sale lease-back transactions, tax issues inreal estate litigation, taxation of Real Estate Investment Trust (REITs) and Real Estate Mortgage Investment Conduits (REMICs), taxation of cooperatives and their members, taxation of condominium and homeowner associations, rental of a residence, business use of a residence, and advanced Section 1034 problems. 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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2.00 Credits
Description: The course concentrates on non-qualified deferred compensation, contribution limitations and benefit distribution opportunities with respect to qualified deferred compensation plans, fringe benefits including welfare benefit plans, non-discrimination tests, and all aspects of equity compensation including stock bonus plans and stock options (incentive stock options and non-statutory stock options). 2.00credit(s) Restrictions: Must be enrolled in one of the following Levels: Undergraduate
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