Income Tax Planning Workshop
Requisite: Federal Income Tax
Emerging technologies enable new ways of doing business - such as internet selling, cloud computing and telecommuting - that increase the number and complexity of cross-border transactions. Because these transactions challenge traditional theories of taxation, taxing jurisdictions are aggressively pursuing revenues from business activities with any connection to their borders.
In this workshop, we will use this hot topic of "nexus" (state jurisdiction to tax) to introduce, discuss and hone tax planning skills.
We will focus on developing students' analytical, drafting, negotiating and presenting skills through the production of a series of legal products: a legal memorandum, a tax opinion, a tax contingency memorandum, a tax indemnity, a voluntary disclosure agreement and a board presentation. The workshop aims to enhance students' grasp of practice skills -- as well as the legal reasoning and financial insight demanded of tax counsel. As such, we will also explore the role of tax counsel, consider how uncertain tax positions are accounted for (ASC 740), and discuss problems for the tax practitioner related to the scope of attorney-client privilege.Grading and Method of Evaluation:
Letter grade only. Students will be graded based on written exercises, class presentation and participation.