Taxation of Property Transactions

2 Credit Hours

The first half of the course considers the federal income tax aspects of the acquisition, ownership, and disposition of tangible and intangible property including: concepts of realization and recognition of income and loss; basis of purchased property and the basis of property acquired by gift or by bequest; capitalization; cost recovery; acquisition and disposition of property subject to liabilities; mechanics of capital gains and losses; the effect of depreciation and depreciation recapture; installment sales and open transactions; imputed interest, and original issue discount. The second half of the course considers limitations on tax shelters and tax-structured transactions including the at-risk, passive activity, and other limitations on loss recognition; limitations on interest deductions; and the tax treatment of leasing transactions including the business purpose and economic substance doctrines, rent-leveling, and loss limitations. PRE-REQUISITES/RESTRICTIONS: BUSCOM 690 Basic Federal Income Tax or enrollment in the Tax LLM program is a pre-requisite for this course. Non-TaxLLM students may not bid on this course, but may enroll during the add/drop period if there are open seats and they have met the pre-requisite.