MSL Initial Courses
The MSL program is 30 units in length. The first three courses that each MSL student studying Taxation will take are: 1) Introduction to US Legal Systems; 2) Legal Writing and Analysis; and 3) Introduction to Income Taxation.
Introduction to US Legal Systems
This course is designed for students who do not have a law degree from a US law school. Students will study the foundational aspects of the US legal system, this includes the structure of government, administrative law, and various foundational aspects of core legal topics relevant to the financial sector.
Legal Writing and Analysis
This course is designed for students who do not have a law degree from an ABA-accredited school. Students will be trained on legal writing, analysis, and "how to think like a lawyer." The goal is to increase competence in these areas to prepare for the core concentration courses in the Master's degree.
Core Concentration Courses
Each student will begin with Introduction to Income Taxation, and end with Thesis. In between, each student will complete at least five of the following core concentration courses.
Individual Income Taxation ITX 684
U.S. Tax introduces the fundamentals of US federal income tax applicable to individual taxpayers. Issues include an overview of the federal tax system; gross income, inclusions and exclusions; identity of the proper taxpayer; concepts and categories of deductions; basic timing principles; tax credits; and the tax aspects of the acquisition, ownership and disposition of property.
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Advanced Income Taxation ITX 626
Advanced Income Taxation addresses the federal income tax aspects of deferred payment transactions and like-kind exchanges, as well as the design and operation of employee benefit plans such as qualified pension and profit-sharing plans, non-qualified plans, and taxation of plan distributions. The second part of the course focuses on tax accounting issues. This course requires Income Taxation (ITX 650) or permission of the instructor.
Civil Tax Procedure ITX 627
An advanced course in tax procedure that addresses the structure of the US tax system; the IRS and other tax collection and enforcement agencies; administrative and judicial tribunals with jurisdiction; dealing with audits; administrative rulings; assessment of deficiencies and penalties; closing agreements; tax liens; statutes of limitation; claims for refund; hearings before the IRS Appeals Office, and civil and criminal aspects of tax fraud; ethical issues in engagement acceptance; confidentiality and the attorney-client evidentiary privilege; conflicts of interest; and tax shelters.
International Taxation ITX 631:
US-International Tax is a United States oriented course rather than a global tax course. The emphasis is upon the federal taxation of (1) the U.S.-related income of nonresident aliens and foreign corporations, and (2) the foreign-related income of U.S. taxpayers. Topics include taxation of outbound and inbound expatriates; the source of income and expense allocation rules; the concepts of "US trade or business" and "effectively connected income," and the effect of a tax treaty; the foreign tax credit; Subpart F, PHC, PFIC and other anti-deferral mechanisms; FDAP income and withholding; foreign investment in U.S. real estate and FIRPTA; and the next generation of Foreign Sales Corporations tax preferences.
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Taxation of Business Entities ITX 628A
The purpose of this course, Taxation of Business Entities, ITX 628-A is to offer students a comprehensive overview of how business entities are taxed including, but not limited to, sole proprietors, partnerships, S-Corporations, C-Corporations and Limited Liability Companies (LLC’s). In addition to learning how business entities are taxed, the student will comprehend how the entities differ in reporting taxes. For instance, sole proprietors are taxed differently than partnerships, corporations and LLC’s; thus, those differences will be presented to the students in a manner which is easily comprehended. Further, a brief discussion on how other types of entities are taxed will also be offered in the course.
In addition to learning the differences on how business entities are taxed, students will be given instructions on which forms are used by the business entities for federal taxing purposes. For example, the Schedule-C is used by sole proprietors, the Form 1065 is used by partnerships, the 1120-S is used by S-Corporations and the Form 1120 is used by C-Corporations. The students will also be given rudimentary instructions on how the forms are prepared and given an opportunity to prepare some of the forms in benchmark assignments. There will also be given a comprehensive assignment in week 8, benchmark 4, which will consist of several questions relating to all the business entities and how they are taxed.
Finally, the students will comprehend as to which entity type is best to use under certain circumstances. For instance, the students will learn that partnerships cannot be used by single member LLC’s. Further, the students will comprehend when to use an LLC in lieu of an S-Corporation, a C-Corporation in lieu of an S-Corporation, etc. Thus, upon completion of the course, the student will understand which forms are used by which business entities, which forms are used by all business entities, such as the Form 4562, and how to complete those forms for clients if such clients seek to have those forms prepared. In addition to learning about tax forms and business entities, the student will understand which entity is appropriate to use for a particular client.
Thesis ITX 654
This final capstone course is required to graduate and is offered in every term. It is an advanced research course in which each student must write a thesis of between 12,500 and 25,000 words with a minimum of ten independent sources and 120 footnotes, under faculty supervision. The thesis topic is chosen by the student, subject to approval by the instructor. The student is encouraged to publish the thesis after course completion. The thesis tests the student's ability to independently identify the issue, address a research methodology for the issue, create an outline, think laterally but hone in on the relevant, as well as to produce an article of professional quality. During the course, students will learn advanced research techniques and participate in workshops in which they receive feedback both from the instructor and from other students, including doctoral candidates.
****Except as provided in rule 4.30 of the Admissions Rules (Legal education in a foreign state or country), completion of a professional law degree program at this law school other than for the Juris Doctor degree does not qualify a student to take the California Bar Examination or satisfy the requirements for admission to practice law in California. It may not qualify a student to take the bar examination or to satisfy requirements for admission to the practice of law in any other jurisdiction. A student intending to seek admission to practice law should contact the admitting authority in the jurisdictions where the student intends to qualify to sit for the bar examination or to be admitted to practice for information regarding their legal education requirements.
Estate Planning ITX 681
This course is an in-depth study of legal, ethical, and tax issues that arise in the context of estate planning. You will learn about client expectations and ethical considerations that arise while working with individuals and families to achieve their goals. You will explore initial information and contracts that are relevant to the practice of estate planning. You will learn about the probate process, intestacy, methods to avoid probate, and various assets and their transfer rules. You will learn about incapacity planning and crucial healthcare documents used in estate planning. This course will explore gifting and inheritances and will address the gift and estate tax and related income tax issues that arise in the course of planning for individuals and married couples. You will learn about trusts and other techniques used to achieve the client objectives of minimizing taxes and providing asset protection.
Taxation of Investments ITX 686
Taxes effects entities on all levels, from individuals and small businesses to large corporations. Taxes also affect investment decisions and the value of compensation and benefits received by employees. This course explores the tax implications of a variety of common individual and business investment activities. This course seeks to develop a conceptual understanding of the federal income tax system and to provide a framework for integrating income tax planning into the investment decision-making process. This course is designed to help students anticipate the impact of taxation on activities and seek alternatives that maximize the use of pre-tax dollars and the after-tax value.