Baruch College Summer 2012

City University of New York

COURSE OUTLINE
Current Problems in Taxation TAX 9889
Monday, Wednesday & Thursday 6-8:30pm
Room 3-150 VC

Professor: Darryl Steinberg
E-mail: Darryl.Steinberg@cuny.baruch.edu

Optional Texts: Smith, Wests Internal Revenue Code of 1986 and Treasury Regulations:
Annotated and Selected (West Federal Taxation, 2012 Ed.).

Mission Statement, Stat Ross Department of Accountancy: The missions of the Stan Ross
Department of Accountancy are (1) to operate the undergraduate, masters and doctoral programs
in accountancy, (2) to provide accounting knowledge to students with majors in areas other than
accounting, and (3) to serve its student, academic, and business constituencies through
engagement in high quality research. Consistent with the Zicklin Schools mission, the
Department seeks to provide high quality, high value education to enhance the professional aims
of its students.

The Departments masters programs in accountancy seek to expand the knowledge and skills
that students bring from undergraduate school and the workplace.

Course Description and Learning Goals: This is an advanced course, which assumes prior or
co-requisite knowledge of federal income taxation. This course deals with an eclectic selection of
problematic areas of taxation and provides an in depth discussion of each. The learning goals of
the course are to provide an in-depth understanding of these various topics so that students can (1)
be more informed and effective as practitioners in the fields of tax, accounting or general
business; (2) be better able to recognize and evaluate legal and ethical tax issues regarding these
issues; and (3) be more creative as tax planners.

Class Syllabus (Reading material for each subject matter will be assigned and/or
distributed to the class each Friday prior to the following weeks lectures):

Introduction/Course Overview Class #1, June 4

Tax Reform Background/Historical Overview of Current Tax System Class # 2, June 6

Tax Reform Proposed Alternatives; Corporate & International Tax Reform Class # 3, June 7

FBAR/FACTA Class # 4, June 11

IRS Response to the Financial Crisis of 2008 Class #5, June 13

US & Foreign Tax Issues Associated with Alternative Energy Class #5, June 14

US Foreign Tax Credit Generator Transactions & Economic Substance Doct Class #6, June 18

US Taxation of Equity Derivatives & IRC Section 871(m) Class #7, June 20

Advanced Concepts in State and Local Taxation Class #8, June 21
US Taxation of Debt Instruments Special Rules for Non-Standard Debt Inst Class #9, June 25

US Transfer Pricing Class #10, June 27

US Taxation of Distressed Debt Investing by Hedge Funds & Private Equity Class #11, June 28

Class TBD Class #12, July 2

No Class Class #13, July 4

Reading Period Class #14, July 5



Tests and Grading: Grading for this class will consist of two (2) parts: (1) Meaningful class
participation; (2) a final examination. Class participation is strongly encouraged and will only
count in your favor from a course grade perspective. Class participation could potentially raise
your overall course grade by up to two (2) levels (e.g., from B to A- or B+ to A). The final
examination will count for 100% of the overall course grade and cover all material covered
during the class. All exams are open book/open notes.

Contemporary Topics and Ethics: The course will address contemporary topics and ethical
issues as the subject matter and time may permit. To stay current on tax issues, students may be
interested in reading the tax column that appears on the front page of the Wall Street Journal each
Wednesday or view Tax Notes Today on line. The class is also encouraged to access the
following tax research sources (Accessing Electronic Resources: On Campus From the Newman
Librarys homepage, http://newman.baruch.cuny.edu select Information Resources):

*CCH Tax Research, WestLaw, *Office of Management and Budget
http://www.whitehouse.gov/omb
*U.S. Department of Treasury Taxes http://www.treasury.gov/topics/tax/index.html
*Internal Revenue Service, http://www.irs.gov
*Congressional Resources: U.S. Congress Joint Committee on Taxation http://www.house.gov/jct
*U.S. Senate Finance Committee http://finance.senate
*U.S. House Committee of Ways and Means http://waysandmeans.house.gov

Rita Ormsby is the accounting librarian who is available to assist students in accessing Newman
Library resources: Rita_Ormsby@baruch.cuny.edu.

Academic Honesty: Academic dishonesty is unacceptable and will not be tolerated.
Cheating, forgery, plagiarism and collusion in dishonest acts undermine the college's
educational mission and the students' personal and intellectual growth. Baruch students
are expected to bear individual responsibility for their work, to learn the rules and
definitions that underlie the practice of academic integrity, and to uphold its ideals.
Ignorance of the rules is not an acceptable excuse for disobeying them. Any student who
attempts to compromise or devalue the academic process will be sanctioned. For
further information on matters relating to Student Academic Dishonesty and Student
Affairs, you may go to the Baruch College website at Baruch.cuny.edu and select
Academics and Academic Honesty from the scroll bar, or contact The Dean of
Students Office (646) 312-4570, Room 2-255, Vertical Campus.

Introduction/Course Overview Class #1, Mon June 4

For the initial lecture on June 4th, please read Chapters 1-4 of the
document Simple, Fair and Pro-Growth: Proposals to Fix America's Tax
System. The first week of class we will discuss our current US federal
income tax system and alternatives to it being currently proposed.

The document for Monday's lecture is attached to this email and should
also be in the Course Documents section of Blackboard.

Files:
Simple-Fair-and-Pro-Growth~1.pdf (8 MB ) [Open in Browser ]



Tax Reform Background/Historical Overview of Current Tax System Class # 2, Wed June 6
On next Wednesday, we will continue our general class discussion on US
Tax Reform.

Please read pages 65-94 on Corporate Tax Reform in the Economic
Recovery Advisory Board, The Report on Tax Reform Options (Aug 2010),
attached hereto.

Files
PERAB_Tax_Reform_Report.pdf (2 MB ) [Open in Browser ]

404k Esop Tax Article.pdf (36 KB ) [Open in Browser ]

Tax Reform Proposed Alternatives; Corporate & International Tax Reform Class # 3, Thurs June 7
For Thursday's lecture, we will be discussing recommendations made by
the two tax reform panels. Please skim pages 3-56 in the August 2010
report and skim Chapter 5 in the November 2005 report. I will highlight the
relevant portions during class discussion.

FBAR/FACTA Class # 4, Mon June 11

IRS Response to the Financial Crisis of 2008 Class #5, Wed June 13
In your Course Documents folder, there are 6 files for next Wed, June
13th's lecture: 4 IRS 2008 Notices along with 2 articles, Trampling on the
US Economy and IRS to the Rescue.

For Wednesday's lecture, I've posted on Course Documents four (4)
additional short articles...one from Barrons on US MNCs and Redomiciling
to Avoid US Tax...and three others dealing with the 2008 Wells
Fargo/Wachovia merger.

Files:
http://online.barrons.com/article/SB5000142405311190447020457744652
3380895232.html?mod=BOL_twm_fs#text.email

US & Foreign Tax Issues Associated with Alternative Energy Class #5, Thurs June 14
Daily Tax Report, Lawmakers and Witnesses Debate Impact of Tax
Reform on Energy Policy

Interesting article for tomorrow's lecture...to provide context to our
discussion.

Apologies for delayed circulation.

An additional slide presentation for tonight's lecture.

Files:
WK_Daily Tax Report Lawmak~1.pdf (15 KB ) [Open in Browser ]
Tax Credit Partnerships_ E~1.ppt (985 KB ) [Open in Browser ]

US Foreign Tax Credit Generator Transactions & Economic Substance Doct Class #6, Mon June 18
In addition to the readings below, slides will be circulated for Monday's
lecture.

Stay tuned.
Please read the attached case for Monday's class.

Files:
Notice_of_Proposed_Rulemak~1.pdf (35 KB ) [Open in Browser ]; Rosenbloom FTC Generator A~1.pdf (102 KB ) [Open in
Browser ]
HEWLETTPACKARD Case.pdf (119 KB ) [Open in Browser ]
Foreign Tax Credit Transa~1.pptx (1 MB ) [Open in Browser ]


No class , Wed June 20


Advanced Concepts in State and Local Taxation Class #7, Thurs June 21
Baruch Nexus Presentation.pptx (2 MB ) [Open in Browser ]

Alternative Energy and US FTC Generator lectures review Class #8, Mon June 25

US Transfer Pricing Class #9, Wed June 27

US Taxation of Distressed Debt Investing by Hedge Funds & Private Equity Class #10, Thur June 28
Furci.pdf (72 KB ) [Open in Browser ]


US Taxation of Equity Derivatives & IRC Section 871(m) Class #11, Mon July 2

No Class , Wed July 4

Reading Period Class #12, Thur July 5

Final Class #15, Mon July 9