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Provides the background and ethical framework that governs the practice of tax at both the federal and state levels. Focuses on the rules that govern the conduct of accountants in federal and state tax practice. Includes an in-depth discussion of Circular 230, the AICPA Tax Practice Standards, the state Boards of Accountancy, and state tax agencies' rules and regulations (to the extent that they exist). Covers eligibility to practice in the tax field for federal and state purposes, client confidentiality and related tax-practitioner privileges, managing conflicts of interest, rules governing fees, standards of practice and disclosure on the tax return, new rules on written advice, practitioner penalties and malpractice claims, performing other services (and the unauthorized practice of law), and best practices for tax advisers. Also covers the states' regulation of tax practice, including multi-jurisdictional practice. Focuses on real-life case studies that illustrate the dilemmas faced by tax practitioners in everyday situations, and addresses the practical questions of operating a tax practice.
Prerequisite: TA 318 or equivalent., Units: 3
Analyzes the tax treatment, tax problems and tax-planning techniques of corporations and flow through entities engaged in multistate activities. The course is structured as a survey course and will cover the rules and regulations in multiple states. Students will be able to request coverage of specific states that are of interest to them in their practice. Topics include: Constitutional limitations on states' ability to tax multistate corporations and flow through entities, new developments in state doing business standard, state tax treatment of S corporations, partnerships and LLCs, computation of taxable income, business vs. nonbusiness income, formula apportionment, unitary taxation, combined reporting, consolidated returns and water's-edge elections. Case studies are used to illustrate concepts.
Prerequisite: TA 318 and TA 329., Units: 3 , Offered: Fall 2015
Examines the basics of federal income taxation with emphasis on statutory materials; special attention to problems of individual taxpayers and specific rules regarding gross income, adjusted gross income, taxable income, deductions, exemptions and credits. Students are required to take this course as one of the first two advanced graduate seminars in taxation.
A survey course in the procedural aspects of dealings between taxpayers and their representatives on the one hand and the Internal Revenue Service, IRS Office of Professional Responsibility, the Office of the Chief Counsel for the Internal Revenue Service, and the Tax Division of the Department of Justice on the other hand. It will assist you to understand and prepare to handle practical issues involving your and your clients' or employer's duties, powers, responsibilities, liabilities, privileges, and ethical obligations arising in federal tax practice, including access to information; IRS examinations and appeals; deficiency assessments; interest on underpayments and overpayments; penalties (civil and criminal) against taxpayers, their representatives, and their tax return preparers; statutes of limitations on assessment and collection of taxes and penalties and criminal tax prosecutions; and refund and collection of federal income, estate and gift taxes. Corequisites: TA 318 and TA 329.
Effective 6/17/14 Analyzes the tax treatment, tax problems and tax-planning techniques of corporations and flow through entities engaged in multistate activities. Emphasis is on California law and how it applies to businesses organized or doing business in the state. Topics include: Constitutional limitations on states' ability to tax multistate corporations and flow through entities, new developments in California doing business standard, California tax treatment of S corporations, partnerships and LLCs, computation of income, business vs. nonbusiness income, formula apportionment, unitary taxation, combined reports, consolidated returns and water's-edge elections. Case studies are used to illustrate concepts.
Prerequisite: TA 318 and TA 329., Units: 3 , Offered: Summer 2016
Presents a broad survey of the rules of US income taxation regarding international transactions. It will cover both "in-bound" transactions the treatment of non-resident aliens and foreign corporations investing and/or doing business in the united States, as well as "out-bound" transactions the treatment of US citizens and residents investing and/or doing business outside the US.
Analyzes tax treatment, tax problems and tax planning techniques involving transactions between corporations and their shareholders: transfers to corporation; capital structure; dividends and other distributions; stock redemptions and liquidations; stock dividends and preferred stock bailouts; and introduction to S corporations. Prerequisite TA 330.
Covers specific issues of operating in corporate form: corporate reorganizations and divisions; carryovers of tax attributes; limitations on carryovers.
Prerequisite: TA 322A., Units: 3 , Offered: Summer 2016
Covers the state tax structure applied to individuals, which includes in-depth coverage of issues related to residency and sourcing of income of nonresidents. Also explores the rules in multiple states and analyzes the constitutional limitations on the state's ability to extend its tax system to nonresidents. Covers state sourcing rules that apply to nonresident partners, shareholders and LLC members. The course will also examine issues related to telecommuting and the mobile work force. Also analyzed are the issue of conformity to federal law in light of massive nonconformity by most of the states; tax incentives offered by the states to encourage job growth; and specialized topics such as state taxation of estates, trusts and their beneficiaries, accounting periods and methods and state taxation of taxable and nontaxable sales and exchanges.
Prerequisite: TA 318 or equivalent., Units: 3 , Offered: Summer 2016
Analyzes tax advantages of ownership of real property; how to acquire real property; choice of entity; ownership and operation of real property; sales, exchanges, conversions and abandonments; postponing taxation on sale; tax aspects of mortgage financing; foreclosures and cancellations; leasing real property; hybrid financing through sales and lease backs; partnerships, subdivisions, syndicates, real estate investment trusts; ownership by homeowners associations, co-ops, tax exempt and foreign investors and real estate holding companies.
Prerequisite: TA 329. Corequisite: TA 330, Units: 3
Analyzes tax problems of the organization and operation of partnerships including the treatment of partnership distributions, withdrawal of a partner during his/her lifetime, dissolution of the partnership, sales or exchanges of partnership interests.
Examines the primary sources of income tax law, the IRC, and administrative and judicial interpretations. The research process will be analyzed, using both paper products as well as electronic resources. Practical written and computerized assignments will be completed using research tools to locate, understand and interpret primary source materials. This is a writing intensive course. Students are required to take this course as one of the first two advanced program seminars in taxation.
Analyzes federal income taxation of property transactions, including definition and mechanics of property transactions, definition of capital assets, nonrecognition property transactions, including I.R.C. Sections 121, 1031 and 1033; examination of the at risk and passive loss rules. Corequisites: TA 318 and TA 329.
Analyzes and compares tax-exempt status under section 501(c) of the Code; sophisticated tax planning for charitable contributions; the use of charitable remainder and lead trusts, charitable gift annuities, bargain sales, charitable contributions as a tax shelter; private foundation excise tax problems; unrelated business income problems; special problems and international philanthropy.
Prerequisite: TA 318 and TA 329., Units: 3 , Offered: Fall 2015
Covers the state tax structure applied to all taxpayers, as well as various sources of law in California (and other states). Also covers resources available to locate state tax law on various matters. Examines state tax practice, states that require registration to prepare tax returns and that regulate tax return preparers. Discusses state ethical procedures and rules dealing with such issues as client confidentiality, privileged communication, malpractice and the unauthorized practice of law. Also covers state tax procedure including constitutional authority to tax, limitations on imposing taxes (versus fees) and administrative provisions governing rulemaking. Examines state filing requirements, estimated tax payments and amended returns. Discusses statute of limitations and the audit process, as well as unique state penalties and reporting requirements.
Prerequisite: TA 318 or equivalent, Units: 3
Explores consolidated return law, including concept and history; eligibility to file; computation of consolidated and separate taxable income; intercompany transactions; SRLY rules; consolidated basis adjustments and procedures.
Prerequisite: TA 322A and TA 322B., Units: 3
Examines selected topics in estate planning, including general legal principles relating to estate planning, including a review of relevant, legal documents; lifetime gifting, including utilization of the annual exclusion and alternative forms of wealth transfer; marital deduction planning, including quantifying the deduction through partial QTIP elections, utilization of the TPT credit, and the use of formula clauses; gifts to charity, including the use of both outright and split-interest gifts; the use of life insurance in estate planning; planning for generation skipping transfers; advising elderly clients; and post mortem planning.
Prerequisite: TA 325., Units: 3 , Offered: Summer 2016
Presents a discussion and analysis of the estate, income and excise tax treatment of retirement plans, SEPS and IRAs. Includes various methods of distribution at age 70 1/2, naming of individuals or trusts as beneficiaries, marital deduction and non-citizen spouse issues, comparison of deferral and payment of benefits during life and after death. Emphasis on actual case studies and examples of the interplay between estate and income tax consequences of retirement plans and IRAs.
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. Corequisites: TA 318 and TA 329.
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.
Examines the application of the excise taxes with an emphasis on state and local taxes in Washington state. We will examine the legal authority for state excise taxes. We will review sales, use, and business activity 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 state taxes, including apportionment formulae and recent developments. We will also cover some transactional taxes (i.e. transaction taxes and sin taxes).
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.
Prerequisite: TA 318 and TA 329., Units: 3 , Offered: Spring 2016
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.
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.
Focuses on the role, function and uses of income tax treaties. Examines the general aspects of treaties (policy, legal authority and negotiation), the interpretation of treaties, and a detailed examination of the terms of the US Model Income Tax Convention, the OECD Model Tax Convention, the United Nations Model Double Tax Convention between Developed and Developing Countries, as well as selected provisions of current United States treaties in force. Topics include: taxation of investment income (i.e. interest, dividends and capital gains), taxation of license fees and royalties, treaty shopping; limitation of benefits, permanent establishment; taxation of the income of natural persons (i.e. personal services), allocation of income between related parties, non-discrimination toward foreigners and recent treaty developments.
Units: 3 , Offered: Spring 2016
Provides an in-depth coverage of intercompany pricing rules, including intercompany sales, loans, services, leasing, and transfers of intangibles. Discussion of intercompany sales cases, as well as the treatment of intercompany loans under the imputed interest and below market loan provisions. Examination of advance pricing agreements and relevant treaty provisions.
Prerequisite: TA 321., Units: 3 , Offered: Spring 2016
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.
Prerequisite: TA 350A and TA 350B., Units: 3 , Offered: Fall 2015
Provides a comprehensive examination of the tax issues confronted by companies engaged in electronic commerce, with special attention to remote sellers. Areas of taxation studied include state sales tax, state income tax, cross-border (international) transactions, tax accounting for web site development costs, acquisitions and dispositions of web-based businesses, valuation issues and tax compliance associated with e-commerce. The course emphasizes six unique aspects of e-commerce taxation, including: worldwide reach of web sites, anonymous transactions, digital products, remote operation of a web server, intangible assets in web sites, and fast-changing rules.
Prerequisite: TA 318, TA 322A, TA 329 and TA 330., Units: 3 , Offered: Summer 2016
Examines and compares the entity classification of the S Corporation versus the Limited Liability Corporation. Explores the tax treatment, problems and planning techniques of formation and operation of both entity forms, including eligibility, election, revocation, termination and accounting rules. This is a highly recommended elective course.
Provides a basic overview of the basics of bankruptcy, insolvency and pre-bankruptcy planning for individuals, corporations and partnerships. This overview includes the differences between bankruptcy Chapters 7, 11, and 13, the workings of the automatic stay, offsets, priorities, and the creation of the separate bankruptcy estate and liquidating trusts. The course will examine the tax and bankruptcy treatment of debtors, claims of creditors, tax-free bankruptcy reorganizations, survival of tax attributes and pre-and post-petition debt discharges and the role of the tax professional. The course includes Case Study reviews of current significant corporate bankruptcies, including associated Disclosure Statements, Plans of Reorganization and petitions in order to appreciate the form that tax-sensitive documents are presented and to analyze the various tax consequences of bankruptcy discharges to debtors, creditors and interest holders such as shareholders.
Prerequisite: TA318 and 329. Recommended: TA319, Units: 3
Examines the financial accounting and reporting of income taxes under Statement of Financial Accounting Standards Codification Topic 740 (FASB ASC 740) formerly known as FAS 109 and related accounting literature. Topics include the calculation of current and deferred income taxes, an overview of book-tax differences, the calculation of interim period tax provisions and the presentation and disclosure of income taxes in financial statements. Students will learn the basics of accounting for income taxes related to advanced topics such as stock compensation expense, foreign operations, state income taxes and accounting for uncertain tax positions (formerly known as FIN 48). The difference between US and international accounting standards will be identified and discussed.
Examines the tax aspects of financial instruments, products, and transactions. Also covers basic principles, including financial terminology, types of market participants, as well as the tax concepts of timing, character, and source. The course will be divided into three broad categories: Equity, Debt and Derivatives. Students will study the detailed rules regarding the tax treatment of financial instruments including stocks, bonds, options, forward contracts, futures contracts, convertible and contingent payment instruments, swaps, and hybrid instruments. Tax issues that will be addressed include wash sales, constructive sales, short sale rules, straddles, market discount, original issue discount, Section 1256 and notional principal contract regulations.
Studies in-depth employee benefit and compensation plans and their regulation under the Internal Revenue Code of 1986, as amended (the Code), and the Employee Retirement Income Security Act of 1974 (ERISA). The course will be taught from a workbook, handbook and relevant cases. Students will work extensively with the Code and ERISA.
Addresses significant, topical and practical problems, issues and theories in taxation. Topics are compiled and selected by the dean. This course may be taken more than once, provided the same topic is not repeated. Prerequisites will vary based on topic.
Includes extensive discussion of combined reports, consolidated returns, separate returns and issues related to going from the federal consolidated return to the state return. Covers deferred taxes (and related ASC 740 analysis), mergers and acquisitions (and NOLs), and international issues as they relate to SALT. Discusses Waters Edge Election, tax incentives related to business entities, and organizing and operating a state and local tax department.
Prerequisite: TA 320, Units: 3
Covers various compliance issues in international taxation. Students should gain hands-on experience with major international tax compliance forms, schedules, statements and calculations, gain practical tips on common errors and compliance traps, and receive instructions on annual compliance updates. Each compliance topic will be taught using one or multiple PowerPoint presentations and be illustrated by one comprehensive (or in-depth) case study (where appropriate).
Prerequisite: TA 321., Units: 3 , Offered: Fall 2015
An in-depth study of various elements that make up an employee compensation and benefit package and their regulation under the Internal Revenue Code (the "Code"). Topics covered in the first half of the course will include basic compensation arrangements, bonus plans, nonqualified deferred compensation, severance plans and various forms of equity compensation (such as stock options and restricted stock). The second half of the course will focus on health and welfare coverage, including medical benefits, disability programs, life insurance, flexible spending accounts and cafeteria plans. Taught from a workbook. Students will work extensively with the Code and also with the Employee Retirement Income Security Act of 1974 (ERISA).
A companion course to TA 396LS - Leadership Speaker Series. We will use the speakers at the weekly Leadership Speaker Series as a jumping off point for the leadership theories we will explore. The purpose of this course is to introduce students to theories of leadership which will inform and guide students in their personal lives and professional practice as leaders. The course will examine primary styles of leadership and each week, using independent research, students will have the opportunity to apply these theories through case analysis of the speakers and to enhance personal skill development through reflective-leadership practice.
Units: 2 , Offered: Spring 2016
Provides the background and ethical framework that governs the practice of tax at both the federal and state levels. Focuses on the rules that govern the conduct of accountants in federal and state tax practice. Includes an in-depth discussion of Circular 230, the AICPA Tax Practice Standards, the state Boards of Accountancy, and state tax agencies' rules and regulations (to the extent that they exist). Covers eligibility to practice in the tax field for federal and state purposes, client confidentiality and related tax practitioner privileges, managing conflicts of interest, rules governing fees, standards of practice and disclosure on the tax return, new rules on written advice, practitioner penalties and malpractice claims, performing other services (and the unauthorized practice of law), and best practices for tax advisors. Also covers the states' regulation of tax practice, including multi-jurisdictional practice. Focuses on real-life case studies that illustrate the dilemmas faced by tax practitioners in everyday situations, and addresses the practical questions of operating a tax practice.
Examines planning for the repatriation of previously U.S. tax deferred foreign earnings by U.S. business enterprises. Compares various repatriation strategies including dividends, loans, use of hybrid instruments, investment in U.S. property, inbound liquidations of foreign subsidiaries, inbound mergers, sales of shares of foreign corporations, and check the box elections. The course also covers selected foreign tax credit topics including credit splitting events, reduction in credits in covered acquisitions, deferral of credits generated by investments in U.S. property and allocation and apportionment of deductions for foreign tax credit limitation purposes.
Prerequisite: TA 321, Units: 3
Introduces students to the many unique issues and options that may or may not be available depending on the ownership to the accounting for the vineyard development process. Covers the ongoing accounting once the vines are producing grapes and again what opportunities there may be if the grape grower further processes the crop into wine; the unique challenge of tracking the inventory cost when the wine production period frequently spans several tax years and the various options and tax planning that may be available to certain taxpayers during the winemaking period; and the myriad of special exceptions and benefits that apply to qualifying farmers and many different definitions of what/who is a farmer for differing provisions in the Internal Revenue Code. Students should be familiar with tax issues for the various forms of business entities and basic accounting methods prior to taking this class.
Prerequisite: TA 322A and TA 328 or consent of the dean., Units: 3
A weekly lecture series in which featured speakers highlight personal and professional accomplishments that have shaped their leadership philosophies. The series is open to the public and can be taken as a one-unit course--credit/no credit. If taken for credit, attendance at all lectures is mandatory (though one excused absence is allowed). The speaker series can also be combined with TA 396EL for 3 units.
Units: 1 , Offered: Fall 2015
Covers international wealth and income tax planning for high-net-worth and high-income individuals. Examines two paradigms: 1) a US citizen or resident who invests overseas or moves overseas to live or work; and 2) a non-resident alien who invests in or moves to the United States. Considers in detail the US tax treatment of grantors, trustees and beneficiaries of foreign trusts and the special tax treatment of US citizens who renounce US citizenship, and resident aliens who surrender their permanent residence visa (green card). Also covers the special reporting of foreign financial assets required by US persons, and withholding documentation required by withholding agents before making payments to foreign persons.
Prerequisite: TA 321. TA 325 is recommended., Units: 3
This course will explore the advantages and disadvantages of S corporation status, including analytical and practical guidance regarding planning opportunities and pitfalls associated with forming and operating an S corporation.
Prerequisite: TA 322A and TA 328., Units: 2
Explores the venture capital industry, focusing on the tax issues associated with fund formation, investments, exit events, general partner and manager terms and conditions, allocations, distributions and liquidation. The course follows the life cycle of a venture capital fund to provide students with an integrated understanding of the taxation of the venture industry.
Prerequisite: TA 328 or Dean's approval., Units: 1
Analyzes the various types of sales taxes and use taxes imposed by 46 states. Specifically, students will analyze which party, the buyer or seller of tangible personal property or provider or recipient of taxable services, is responsible for the tax. Course will focus on the impact of sales and use taxes on selected transactions, including interstate purchases and sales, including drop shipments; purchases from and sales to state and federal governments; occasional sales or casual sales; leasing transactions; construction contractors, as well as other areas. There will be a focus on current developments, including the Streamlined Sales Tax Project.
Prerequisite: TA 329., Units: 3 , Offered: Fall 2015
Examines the taxation aspects of Individual Retirement Accounts ("IRAs") and tax-qualified retirement plans. Since both are the primary means by which individuals in the United States save for retirement, and are a primary method by which employers provide benefits to their employees the course will focus on the tax implications of these arrangements for both individuals and employers. The course will also consider significant design issues: how to select and design an appropriate IRA or plan for an individual or for a company, forms and time of payments and various legal requirements. This course will enable students to advise prospective clients (both individuals and employers) on choosing, implementing and maintaining the proper plan for their particular circumstances.
Prerequisite: TA 318, TA 329., Units: 3
Offers students the opportunity to receive graduate-level tax work experience in an accounting firm setting. Available only for students without significant prior tax work experience. Students are responsible for your own placement in an internship, subject to approval by the dean. A written internship proposal is required before consideration for this course. A resume and offer letter are required before being allowed to register. A written report and employer evaluation is required upon completion of the internship. Student eligibility: Completion of 5 of the graduate-level courses required for the MS in taxation degree; GPA of 3.0 or better; no professional work experience in the area(s) upon which the internship work will focus.
Provides an opportunity for the advanced student with a specific project in mind to do reading in a focused area and to prepare a substantial paper under the direction of a faculty member. Only one directed study course may be taken for credit toward a masters degree.
Prerequisite: Completion of six graduate Taxation courses and consent of the dean., Units: 1 - 3