Course Catalog

 

LLM 334A - Advanced Estate Planning

This course takes a comprehensive and detailed look into issues such as charitable organizations, valuation discounts, domestic partnerships, family limited partnerships, guardianships and conservatorships, trust and estate litigation, representing high net worth clients, irrevocable trusts, and law office management. Prerequisites: Estate and Gift Taxation; Estate Planning. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Summer 2010  

LLM 321C - Advanced International Tax

This course explores the interplay among U.S. and international tax, legal, and business considerations in formulating an overall tax-efficient global strategy. Students will explore a variety of international tax topics in a case study format. Topics may include subpart F, foreign tax credits, foreign currency, hybrid instruments, choice of entity issues, international corporate reorganizations, tax treaties, and concerns of foreign investors in the U.S. Prerequisite: International Taxation. Recommended: Corporate Tax. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 326A - Advanced Real Estate Taxation

Prerequisites: Real Estate Taxation and Characterization of Income & Expenditures or Federal Income Taxation.
Credit: 1 Units  

LLM 317B - Advanced Tax Research

Advanced Tax Research offers students the opportunity to put what they learned in Tax Research to practical use in an individual study context. On a topic of their choosing, students write a paper or create a study guide that demonstrates mastery of the multitude of tax research material that exists in print and online. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 - 2 Units  

LLM 346W - Bankruptcy Taxation

This course focuses on the basic rules for bankruptcy (corporate, partnership and individual) and the important interplay between taxes and bankruptcy. The course will cover the discharge of income and other taxes in bankruptcy, and analyze special tax rules applicable to bankruptcies, including tax rules for real property dispositions in bankruptcy, taxation of individual bankruptcy estates, net operating losses and relief of indebtedness income rules. Current bankruptcy-related legislation and events will be discussed. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Fall 2010  

LLM 348B - California Property Tax

This course provides a foundation in the theory and practice of property taxation for California businesses. During this 5-week session, students will learn the basics of real and personal property taxation and discuss current and relevant legal issues, such as tax compliance issues affecting property valuations, audit administration issues, and tax saving strategies. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Spring 2010  

LLM 330 - Characterization of Income & Expenditure

This course examines the fundamental concepts of federal income taxation, including gross income, business and investment deductions, personal exemptions, and the mechanics of capital transactions. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 301A - Comparative International Tax

This seminar compares current tax law in countries from all parts of the developed and developing world. The course will explore similarities and differences among countries' income and other tax systems and identify the implications for tax practice. Using a structural framework, the course materials include recent cases and commentaries. The seminar will also assess national tax regimes in light of international tax treaty requirements and models (OECD, UN, EU, WTO, etc.).
Credit: 2 Units  

LLM 322A - Corporate Taxation

This course addresses tax treatment, planning techniques, and problems of transactions between corporations and their shareholders, transfers to a corporation, capital structure of corporations, dividends and other distributions, stock redemptions, corporate liquidations, and tax free reorganizations. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010 , Fall 2010  

LLM 399 - Directed Study

A Directed Study is an independent study project for LLM students done under the supervision of a faculty member or supervising attorney for academic credit. Directed Study can be taken for 1 to 3 units. The project can be on any topic agreed to by the student, faculty member or supervising attorney, and the LLM program director. Directed Study can be taken for a letter grade or for a Credit/No Credit grade and must be decided at the time of topic approval. All papers submitted under this program should reflect approximately 70 hours of work per unit of credit.
Credit: 1 - 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 307 - DOJ Internship

This is a competitive placement, one student is selected each semester by DOJ. The student will have the opportunity to complete an internship with the Department of Justice Tax Division office in San Francisco, working directly with attorneys on both civil and criminal tax cases. Interested students should contact the director of the LLM in Taxation Program, for more information. Prerequisite: Characterization of Income & Expenditures and Federal Tax Procedure. This course is graded on a Credit/No Credit basis.
Credit: 2 - 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 340A - ERISA I

This course examines Employees Retirement Income Security Act (ERISA) rules for defined contribution retirement plans and related issues. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Fall 2010  

LLM 340B - ERISA II

This course examines Employees Retirement Income Security Act (ERISA) rules for defined contribution retirement plans and related issues. This class is a continuation of ERISA I (LLM 340A) and will focus on the review of the IRS model provisions for defined contribution plans. Prerequsite: ERISA I.(Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units  

LLM 325 - Estate & Gift Taxation

This course provides an introduction to federal wealth transfer tax, including estate, gift, and generation-skipping transfer taxes. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Fall 2010  

LLM 334 - Estate Planning

This course includes a study of various estate planning topics such as the unified credit, marital deductions, charitable deductions, generation-skipping transfers, life insurance, trusts and their uses, and family limited partnerships. Emphasis is on practical skills needed to create a uniform estate plan. Prerequisite:Estate and Gift Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010  

LLM 334B - Estate Planning for the Blended Family

For estate planners representing blended families such as second marriages, same sex relationships, and families with difficult children, this one-unit course will explore and analyze technical and tax issues surrounding the marital deduction, discretionary trust distributions, retirement plan distributions, community property characterization, tax allocation and payment planning, post mortem planning, death versus divorce and the individual psychologies of the parties. This course will also address ethical conflicts and dissect some "typical" estate planning documents to show drafting modifications appropriate for the blended family. Prerequisites: Estate and Gift Tax; Estate Planning. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Fall 2010  

LLM 334L - Estate Planning Lab

This course uses exercises designed to illustrate the challenges and rewards of the estate planning attorney's professional life. Student participation in role plays and class discussion is required and will be graded. Highly experienced estate planning attorneys will be guest participants and lecturers. The course emphasizes the process of practice, including client communication skills, rather than technical substance or document drafting. Prerequisites: Estate Planning; Estate and Gift Taxation.
Credit: 1 Units   Offered: Fall 2010  

LLM 335 - Executive Compensation

This course considers nonqualified retirement plans including stock option plans, top hat plans, excess benefit plans, and related issues. Prerequisites: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Fall 2010  

LLM 346H - Federal Income Taxation of Limited Liability Companies & S Corporations

This course explores the tax treatment, problems, and planning techniques involving LLCs and S corporations, including eligibility, election, revocation, termination, and accounting rules. Prerequisite: Characterization of Income and Expenditures or Federal Income Taxation; Recommended: Corporate Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Summer 2010  

LLM 319 - Federal Tax Procedure

This course provides an overview of federal tax procedures, including Internal Revenue Service practices and policies and the correlative rights and privileges of taxpayers. Coverage includes the regulatory process, the audit and administrative appeals process, choice of litigation forum, and assessment and collection practices. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Fall 2010  

LLM 344 - Income Taxation of Trusts & Estates

This course analyzes the income taxation of trusts and estates, their creators, beneficiaries, and fiduciaries, including computation of distributable net income, taxable net income, taxation of simple and complex trusts, grantor trusts, and income in respect of a decedent. The course will focus on federal income tax issues, although state taxation of estates and trusts will also be addressed. Prerequisite: Characterization of Income & Expenditures. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Spring 2010  

LLM 321 - International Taxation I

This course provides a basic survey of international taxation law, including source of income and expense allocation rules, international tax credits, transfer pricing, antideferral rules, withholding taxes, income tax treaties, tax incentives, and expatriate issues. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. Recommended: Corporate Tax (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010  

LLM 321E - International Taxation II

Detailed review and analysis of the anti-deferral provisions of Subpart F and the Passive Foreign Investment Company ("PFIC") rules. Analysis of the asset and stock cross-border rules of Sec. 367 and Sec. 1248. Overview of transfer pricing provisions as related to anti-deferral provisions. Prerequisites: International Tax I and Corporate Tax.
Credit: 2 Units  

LLM 309 - IRS Internship

This is a competitive placement as an unpaid law clerk with the Internal Revenue Service Office of Chief Counsel in San Francisco or San Jose. Selected students will work directly with IRS counsel on pending Tax Court, collection and other current cases. The placement may be with either SB/SE and LMSB divisions. An IRS background check is required before beginning the internship; interested students should submit a resume and cover letter to the Associate Dean of the Tax LLM Program at the beginning of the semester prior to semester in which the student seeks the internship. Prerequisites: Federal Tax Procedure; Characterization of Income and Expenditures. This course is graded on a Credit/No Credit basis.
Credit: 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 393 - Judicial Externship

This is a competitive placement as an unpaid law clerk with the Probate Department of the California Superior Court of Alameda County. Selected students will work directly with the probate judge, probate examiners, court investigators, and courtroom staff on pending estate, trust, and conservatorship cases. The externs will get hands-on Probate Court experience from the judicial perspective. The course provides invaluable insight for future estate planners. Prerequisites: Estate and Gift Taxation; Estate Planning; Probate Procedure and Litigation. Enrollment in this course requires the permission of the program director of the LLM in Taxation Program. This course is graded on a Credit/No Credit basis.
Credit: 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 346B - Marital Taxation

This course considers the tax consequences of marriage, divorce, and nonmarital relationships, including marital status, prenuptual agreements, interspousal property transfers, structuring divorce settlements, special asset valuation, and the impact of marital status on gift and estate planning. Prerequisite: Characterization of Income and Expenditures. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 351 - Multinational Estate Planning

This course addresses estate, inheritance, gift, and income taxation of trusts and estates as they relate to U.S. citizens living abroad, foreign nationals in the United States, and nonresident aliens. Analysis includes comparative law, estate and gift tax treaties, conflicts of law, and choice of law in selected jurisdictions. Prerequisite: Estate & Gift Taxation; Estate Planning. Recommended: Income Taxation of Trusts & Estates; International Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Fall 2010  

LLM 328 - Partnership Taxation

This course concerns tax issues of the organization and operation of partnerships, including contributions, distributions, withdrawal of a partner, dissolution, and sales or exchanges of partnership interests. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation.(Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010  

LLM 359 - Practical Accounting for Tax Attorneys

This course focuses on basic financial statement analysis and accounting concepts. The course is designed for students who need an understanding of accounting principles. Students planning to do transactional or litigation work where critical reading of financial statements is important will benefit from the course. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 347B - Principles of Valuation

A general survey of valuation for income tax purposes including a study of reasons for valuations, the methods used to measure value, and why income tax valuation may differ from transaction valuation. The course will also cover how to analyze complex income tax valuation disputes and current income valuation insights. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units  

LLM 306 - Pro Bono Tax Clinic

The Pro Bono Tax Clinic provides students with the opportunity to assist low-income individuals in certain tax disputes before the California Board of Equalization ("BOE"). Under the direct supervision of a BOE attorney, the students provide legal assistance to taxpayers with claims involving California tax issues. The students meet regularly with a BOE attorney on campus who instructs them about the relevant law and assists them in the development of their clients' factual and legal arguments. The students draft procedural letters, legal memoranda and briefs that are submitted to the BOE. Students may also have the opportunity to argue the client's case at a BOE hearing. Recommended: Characterization of Income & Expenditures or Federal Income Tax. This course is graded on a Credit/No Credit basis. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 - 2 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 334C - Probate Procedures & Litigation

This course provides an understanding of what happens once the estate plan becomes a decedent's estate needing administration in the Probate Court. Students survey the California Probate Code rules and procedures as they relate to the administration of decedent's estates and trusts. Significant and recurring issues and trends in probate litigation are studied. Prerequisites: Federal Tax Procedure, Estate and Gift Taxation; Estate Planning. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010 , Fall 2010  

LLM 300 - Professional Responsibility for Tax Practitioners

This course considers tax practice issues including tax attorney regulation and ethical considerations. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Spring 2010 , Summer 2010  

LLM 326 - Real Estate Taxation

This course explores the tax advantages of owning real property, acquisitions, operations, sales and exchanges, conversions and abandonments, aspects of financing, leasing, and forms of entity ownership of property. Prerequisites: Characterization of Income & Expenditures or Federal Income Taxation; Recommended: Corporate Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 3 Units   Offered: Spring 2010  

LLM 368 - State & Local Taxation

This course provides an overview of state and local taxation with an emphasis on federal constitutional limitations on state and local taxation, the jurisdiction to tax, apportionment and allocation of the tax base, and an introduction to multistate business taxes, sales and use taxes, corporate income taxes, and individual income taxes. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Spring 2010  

LLM 325A - Tax Aspects of Charitable Giving

This course will provide an in-depth analysis of income, estate, and gift tax issues arising in the context of gifts to charity. Basic rules of charitable giving, including analysis of contributions that will and will not give rise to tax benefits, permissible beneficiaries, limitations based on adjusted gross income and other considerations, valuation and substantiation will be presented. In addition, charitable giving techniques will be discussed, including charitable lead trusts, charitable remainder trusts, and bargain sales. Specific giving situations relevant to estate planning will also be covered. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. Recommended: Estate and Gift Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 326C - Tax Credits for Real Estate Investment

This course is an introduction to low income, rehabilitation, new market and renewable energy tax credits and their use in financing real estate investments. The course covers the basics of what the credits are and how and why they are used, as well as the legal and regulatory parameters, including the use of partnerships as a vehicle for using credits, and discussion of the social policies the credits are designed to advance. Prerequisite: Real Estate Taxation.
Credit: 1 Units  

LLM 331 - Tax Exempt Organizations

This course provides an overview of the laws governing tax-exempt organizations, focusing on federal tax laws affecting charitable and educational organizations. Topics covered include charitable planning, charity formation and application for exemption, operational requirements, executive compensation, private foundation excise taxes and prohibitions, unrelated business income, and other interesting tax issues. The course will also include discussion of relevant state law formation and governance issues as well as charitable trust restrictions, using California as a model. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Summer 2010  

LLM 397 - Tax Fieldwork

Clinical fieldwork in a tax practice may be performed under the supervision of a practicing attorney. Students must petition to program director for approval. This course is graded on a Credit/No Credit basis. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 - 3 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 341D - Tax Litigation

After analyzing litigation procedures and rules, students apply them to model cases through pleadings, discovery, pretrial motions, settlement conferences, stipulations, trial strategies, briefs and memoranda, oral arguments, evidentiary hearings, and trials. Prerequisite: Federal Tax Procedure. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 340 - Tax Policy

This course considers utilization of the tax system to achieve public policy goals, including assumptions, problems, and social impacts of alternative public taxation policies. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units  

LLM 317A - Tax Research

This course acquaints students with resources available for tax research, including legislative processes, the Internal Revenue Code, judicial and administrative interpretations, reference services, and electronic research. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 347 - Taxation of Intellectual Property

This course addresses the tax treatment of intellectual property in a wide range of issues including: tax treatment of the development of IP, distinctions between self-produced and purchased IP, tax treatment of sales and other transfers of IP (treatment of a transfer as a sale or as a license, and the significance of this treatment), and the treatment of IP in non-recognition transactions. International tax topics covered will include: sourcing of income from the use of IP, withholding tax and other taxes on royalties, the impact of tax treaties on licensing, development of IP in tax-favored jurisdictions and transfer pricing rules regarding such development, the use of a "buy-in" or "cost-sharing agreement" and current developments regarding these strategies. There will also be brief coverage of state and local issues regarding IP. Prerequisite: Characterization of Income & Expenditures or Federal Income Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Spring 2010  

LLM 339A - Taxation of Mergers & Acquisitions

This course will provide students with a practical understanding of many of the critical tax considerations associated with acquisitions and dispositions. Topics will include structuring considerations for taxable and tax-free transactions, including tax structuring aspects of asset sales, stock purchases, and mergers, tax due diligence, and drafting and review of acquisition agreements. Prerequisites: Characterization of Income & Expenditures or Federal Income Taxation. Recommended: Corporate Taxation. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Fall 2010  

LLM 315 - Taxation of Securities

Prerequisites: Characterization of Income & Expenditures or Federal Income Taxation.
Credit: 1 Units  

LLM 386 - Thesis

A thesis is an independent study project for LLM students done under the supervision of the LLM Program Director. Thesis can be taken for 4-6 units. The thesis can be on any topic agreed to by the student and the Program Director. Thesis can be taken for a letter grade or for a Credit/No Credit grade and must be decided at the time of topic approval. All papers submitted under this program should reflect approximately 70 hours of work per unit of credit.
Credit: 4 - 6 Units   Offered: Spring 2010 , Summer 2010 , Fall 2010  

LLM 338 - Timing of Income & Expenditure

This course analyzes problems of allocation income and deduction items to the proper taxable year, including annual accounting concept, tax year selection, accounting methods, and the time value of money. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 2 Units   Offered: Spring 2010 , Summer 2010  

LLM 321D - Transfer Pricing

Transfer pricing has emerged as one of the leading international tax issues among multinational corporations. This course covers the genesis of transfer pricing under U.S. law and the legal and economic principles governing inter-company pricing of intangible property, services, and tangible goods transactions. Prerequisites: Characterization of Income & Expenditures or Federal Income Taxation. A background in international taxation, economics, and accounting is useful but not required. (Offered through the LLM in Taxation Program. JD students seeking to enroll must obtain the approval of the program director.)
Credit: 1 Units   Offered: Spring 2010