Course Descriptions
All LLM courses are 2 units each.
Prerequisite Course
Income Taxation I or its three semester-unit equivalent from another institution is a prerequisite for matriculation into the program. Students who have not completed an introductory US federal income tax law course of at least three semester units prior to entry into the program must meet this requirement by taking Loyola's Income Taxation I as special students during the spring or summer term prior to matriculation, or concurrently with other LLM courses in the semester in which they begin the program. In no case will this course count towards the 24 units of coursework required for the LLM.
Required Courses
Corporate Taxation I - Fundamentals of federal income taxation of corporations and their shareholders, including formation, capital structure, nonliquidating distributions, redemptions, liquidations and Subchapter S.
Corporate Taxation II - Advanced topics in the federal income taxation of corporations and their shareholders, including stock dividends, the dividends-received deduction and advanced issues in redemptions and liquidations.
Prerequisite: Corporate Taxation I
Income Tax Timing Issues - Advanced topics in federal income taxation, including accounting methods and interest imputation.
Income Taxation of Property Transactions) - Federal income tax treatment of sales and other dispositions of property, including deferred payment sales, non-recognition transactions of individual taxpayers and depreciation recapture. Students will be asked to research and prepare a tax memorandum.
Partnership Taxation I - Fundamentals of federal income taxation of partners and partnerships, including classification, formation, operations, allocations and related party transactions.
Partnership Taxation II - Further topics in the federal income taxation of partners and partnerships, including distributions, dispositions of partnership interests, terminations, mergers, divisions, the hot asset rules and problems arising out of the death or retirement of a partner. Prerequisite: Partnership Taxation I
Tax Practice and Procedure - Administrative determination of liability, penalties, and interest, civil tax litigation, IRS summonses, limitation periods and their mitigation, collections and administrative rulings and rulemaking.
Elective Courses
Bankruptcy Taxation - Tax issues in bankruptcy, including the treatment of tax claims, the exclusion of debt cancellation from income, taxation of the bankruptcy estate, tax attribute reduction and special issues affecting corporations and partnerships in bankruptcy.
Criminal Tax Practice and Procedure - Federal criminal tax law and procedure, including the prosecution and defense of Title 18 and Title 26 criminal tax offenses, federal and local rules of criminal procedure, pre-trial practice, methods of proof, representation of witnesses, federal sentencing guidelines and related civil considerations.
Directed Tax Research - Supervised preparation of a substantial paper.
Employee Pensions and Benefits - Federal income taxation of qualified and non-qualified plans, participants, and beneficiaries and other employee benefits, including coverage and discrimination rules and limitations on benefits, contributions and funding.
Estate and Gift Taxation I - Fundamentals of federal transfer taxation, including the gift tax, the annual exclusion, estate taxation of property owned by decedent at death, estate taxation of transfers during life, the marital deduction and other deductions and credits.
Estate and Gift Taxation II - Advanced topics in federal transfer taxation, including valuation, charitable giving, the generation skipping transfer tax and transfer tax audit and procedure. Prerequisite: Estate and Gift Taxation I
Estate Planning - Personal planning techniques, including marital deduction planning, techniques for avoiding probate, the use of life insurance, postmortem planning and drafting issues.
Prerequisite: Estate and Gift Taxation I; Prerequisite or concurrent: Estate and Gift Taxation II
Estate and Probate Planning, Practice and Procedure- Students will study the differences between probate estate and estate for federal estate tax purposes, techniques for handling probate issues (including probate litigation of contested issues) and their impact on the estate tax return, and other estate tax return preparation issues, including valuation.
Prerequisite: Estate and Gift Tax I. Recommended: Wills and Trusts
Executive Compensation – Income tax consequences and regulatory implications of executive compensation arrangements, including nonqualified deferred compensation; restricted property; stock options; stock appreciation rights; phantom stock arrangements; the limitations on the deductibility of executive compensation; and golden parachutes payments. The course will also cover non-tax issues that materially influence executive compensation arrangements, including financial accounting, ERISA, securities laws, stock exchange requirements, and the perspectives of shareholders and other parties having an influence on executive compensation.
Honors Tax Policy Colloquium – The course is intended to expose J.D. and Tax LL.M. students to cutting-edge contemporary tax scholarship. After a brief introduction to tax policy concepts and vocabulary, it will consist of presentations and discussions of cutting-edge tax scholarship by professors from schools around the country.
Honors Tax Research - Supervised preparation of a substantial scholarly paper. Prerequisite or concurrent: Tax Policy
Income Taxation of Trusts and Estates - Federal income taxation of trusts and estates, including the computation of taxable income and tax liability, distributable net income, distributions, grantor and controlled trusts, foreign, charitable and other special trusts, and income and deductions in respect of a decedent.
Income Taxation Planning for Real Estate Transactions - Issues in taxation of real estate transactions, including installment sales, foreclosures, like-kind exchanges and involuntary conversions, and operation and development issues including financing, deductions, capitalization, at-risk, and passive activities.
International Taxation I - Fundamentals of the US federal income taxation of international transactions, including the conceptual structure of the basic U.S. rules, taxation of nonresident alien individuals and foreign corporations, the foreign tax credit and transactions in multiple currencies.
International Taxation II - Advanced topics in the U.S. federal income taxation of international transactions. A problem-based course, focusing on US tax issues commonly faced by multinational businesses.
Prerequisite: International Taxation I
Nonprofit Tax and Transactions Clinic – Live client representation clinic in which students provide transactional, non-litigation and non-dispute oriented work involving nonprofit formation, governance, tax-exempt status and operation of nonprofit organizations serving low-income clients or otherwise addressing issues dealing with poverty.
State and Local Taxation - Exploration of the principal types of taxes imposed by state and local governments, including income, corporate franchise, sales and use, property, and transfer taxes, the apportionment of taxes on interstate and foreign commerce and constitutional limitations on state and local taxation.
Tax Aspects of Business Planning - Problems in choice of entity, capital structure, compensation of key employees and exit strategies.
Prerequisite: Corporate Taxation I; Prerequisite or concurrent: Partnership Taxation I
Tax Aspects of Mergers & Acquisitions Transactions - Federal income tax treatment of taxable stock and asset acquisitions, tax-free reorganizations, acquisitions, dispositions, and spin-offs and the carryover of corporate attributes.
Prerequisite: Corporate Taxation I; Prerequisite or concurrent: Corporate Taxation II
Tax-Exempt Organizations - Organizational and operational requirements for organizations exempt from federal income tax, private foundations rules, unrelated business income tax and income, estate and gift tax deductions for charitable contributions.
Tax Externship - Approved off-campus placement for one semester in judicial chambers, government agency or public interest law firm offering experience relevant to student’s training in tax.
Taxpayer Appeals Assistance Clinic – Live client representation clinic in which students assist taxpayers with their state income tax appeals before the California State Board of Equalization, gaining practical experience and knowledge about preparing an appeal and representing taxpayers before the State Board of Equalization.
Tax Policy - Major topics in tax policy, which may include the comprehensive tax base, the tax expenditure budget, distributive justice, incidence, distortion, the taxable unit, alternatives to the income tax and the tax legislative process.
Tax Strategies for the Digital Age - Tax strategies and transaction analysis covering the development, purchase, licensing and sale of rights in films, music, digital media, technology, software, trademarks and Internet commerce.