This course examines the federal income taxation of partnerships and their partners. The universe of businesses subject to partnership tax has been steadily increasing, and includes not only traditional partnerships and limited liability companies but also more exotic arrangements such as domestic and international joint ventures. The course emphasizes the policy choices that lend structure and coherence to many of the specific details of the law, and uses problems to illustrate the basic principles. Partnership transactions are considered in a building-block order, progressing from basic to more complex transactions, to help demonstrate that a given transaction may be structured in different ways to achieve different tax goals, and that the taxation of complex transactions to some extent flows naturally from how simpler ones are taxed. Because the course draws heavily from basic tax concepts, students should have already taken Federal Income Tax, but no other special background (e.g., accounting or partnership law) is necessary.
Flex exam at end of semester.
*Yes means professor requires everyone in the course to submit a substantial research paper (which is the requirement standard in Academic Policies), so no paperwork required to be submitted to SRO. No means student must timely submit paperwork to SRO if intending to use a paper in this course to satisfy the Writing Requirement.
**Yes indicates course credits count towards UVA Law’s Prof. Skills graduation requirement, not necessarily a skills requirements for any particular state bar.