ACCT 6613                
TAXATION OF CORPORATIONS AND THEIR SHAREHOLDERS
Spring 2005

 

Instructor:  Andrew D. Cuccia, CPA, Ph.D.	Office: 202A Adams Hall
Time:  TR 4:30-5:45 PM	Location: 212A Adams HALL
Office Hours:   3:00-4:15 PM.                              or by appt.	Phone:     325-5796  E-Mail:   CUCCIA@OU.EDU

The corporate income tax is one of the best examples in American political history of the law of unintended consequences.

 -John Steel Gordon, author and business historian

Objective: This course is designed to provide an in-depth study of the federal income taxation of corporations and their shareholders.  Specifically, we will examine the tax consequences associated with a corporation’s formation, operations, distributions to shareholders, possible reorganization, and liquidation.  Upon completion of this course students should be familiar with the rules, concepts, underlying policy concerns, and planning opportunities related to the more commonly encountered situations in corporate taxation.  More importantly, the course will provide the tools necessary to analyze new and/or novel situations and opportunities sure to be encountered in practice, and to keep up with the inevitable changes to the law given the dynamic nature of the legislative environment.

Required Materials:
 

S. Lind, S. Schwartz, D. Lathrope, and J. Rosenberg .  Fundamentals of Corporate Taxation (Fifth Edition).  The Foundation Press, Inc., 2002. [LSLR]

2004 Supplement to LSLR

Internal Revenue Code [IRC] (June 2004 or later).  Alternatively, you can access relevant IRC sections from CCH's on-line, web-based tax service, Tax Research Network, via the OU Library web page .  If you are on campus or connecting via the OU modem pool, no password is required.  Access for off-campus users not connecting via the modem pool requires using your “4x4" password.  However, only actual IRCs are allowed as reference materials during exams (see Exams below).

Income Tax Regulations (June 2004 or later).  Again, you can alternatively download relevant sections from the internet.

Assignments and Class Preparation:Daily assignments (see Assignments section) consist of readings from LSLR as well as all problems and IRC and Regulation sections contained therein. 

Class format:   Classes will be primarily student driven, consisting of a combination of discussion and problem solving.  Because our time is limited it is imperative that you be prepared for class meetings.  I will assume all readings and problems have been done IN ADVANCE, and daily activities will be structured accordingly. Classes will routinely be centered around students' briefings of cases presented in the text and discussions of answers to assigned problems.  Participation, in the form of preparedness to present cases and/or problem solutions, will constitute approximately 10 percent of your overall grade.  The success of this class depends not only on the instructor, but the student as well.  Inadequate preparation by either will severely decrease the value of our time together.

Examinations: Two mid-terms and a final examination will be given on the dates indicated on the attached schedule.  Exams will be primarily problem oriented.  You will be responsible for all material covered in class as well as readings, homework, and cases assigned to date.  It is not possible to discuss every topic in-depth in class.  Therefore, it is YOUR responsibility to inquire, either in class or during office hours, about any questions you may have on material not discussed in class.  You are permitted to use your IRC and Regulations, as well as a calculator, during exams.  While writing in either is permissible, reference to neither your LSLR text nor any other notes during exams is allowed.

Mid-term exams will be approximately two hours in length and will extend past the regularly- scheduled class time on the dates noted.  If you have a class conflict with a scheduled exam, advance notice should be given during the first week of the semester.  If you have Provost-approved university-sponsored event or legally required activity that conflicts with a scheduled exam, notice should be given within a reasonable time after the conflict arises.  In any case,  alternative arrangements for the exam will be made.  Otherwise, NO make-up exams will be given. 

Project:  One project will be assigned during the semester. The project will be aimed at exploring firm-specific tax planning strategies and will require each student to report in detail an example of a transaction discussed in class.  Project requirements will be discussed in detail in class.

Grading: Grades are a necessary means of motivation and feedback. In this class, grades will be assigned based on the cumulative score from the following:

Assignment                Points available
Exams (3 @ 150 each)                    450
Projects                                            50
Participation                                      50
Total                                               550

Academic misconduct is defined as any act which improperly affects the evaluation of a student’s academic performance or achievement.  It specifically includes cheating, plagiarism, fabrication, fraud, destruction of property, and bribery or intimidation, as well as assisting others or attempting to engage in such acts.  It is the responsibility of each student to be familiar with the definitions, policies and procedures concerning academic misconduct; and unfamiliarity with the code alters none of a student’ rights or responsibilities thereunder.  The Academic Misconduct Code is printed with the Student Code. 

The University of Oklahoma is committed to providing reasonable accommodation for all students with disabilities. Students with disabilities who require accommodations in this course are requested to speak with the professor as early in the semester as possible. Students with disabilities must be registered with the Office of Disability Services prior to receiving accommodations in this course. The Office of Disability Services is located in Goddard Health Center, Suite 166, phone 405/325-3852 or TDD only 405/325-4173.

Please note that food and drink are prohibited in the classrooms.  The Price College of Business has invested significant resources in improving our classrooms.  Please help us maintain them.