graduate-tax-program

Master of Laws in Taxation for Attorneys (LL.M. Tax)

The LL.M. in Taxation is awarded to those entering the program with a J.D. degree or equivalent. UBalt Law students interested in a joint J.D./LL.M. should discuss the program requirements when scheduling courses for the third semester of law school. To graduate, students must complete all degree requirements as described below, with a cumulative grade point average of 3.00 or better. All requirements must be completed within five years of enrollment. The program's rich and extensive curriculum is described below.

Flexible Options

Attend classes in person, attend classes online in real time, or view recordings of classes. Graduates of J.D. or LL.B programs can receive advanced credit for qualifying tax courses. A concurrent Certificate in Estate Planning is available at little additional cost.

Application Deadlines

Fall: Aug. 1; Spring: Dec. 1; Summer: May 1.
See the admission requirements

Program Costs

Tuition is $1060, plus fees, per credit. This is a flat rate and there is no difference between in-and out-of-state tuition. (J.D. rates apply for courses taken as a J.D. student)
Learn more about tuition and fees

Highlights

In the program, you will:

Program Requirements and Curriculum 

For students who began the program prior to Fall 2022:

To receive an LL.M. in Taxation degree, a student is required to complete thirty (30) credit hours of prescribed coursework and maintain a cumulative GPA of not less than 3.00 for courses taken in the degree program.  Except for advanced credit toward the degree (which is described below), the coursework must be completed after a student has received a J.D. or equivalent degree.  Degree requirements must be completed within five years of enrolling in the degree program.

The program’s curriculum consists of the following required courses, all of which are three-credit courses:     

In addition, students are required to take one or more of the following electives (totaling 9 credits): 

For students who begin the program in or after Fall 2022:

To receive an LL.M. in Taxation degree, a student is required to complete twenty-six (26) credit hours of prescribed coursework and maintain a cumulative GPA of not less than 3.00 for courses taken in the degree program.  Except for advanced credit toward the degree (which is described below), the coursework must be completed after a student has received a J.D. or equivalent degree.  Degree requirements must be completed within five years of enrolling in the degree program. 

The program’s curriculum consists of the following required courses, all of which are three-credit courses:     

In addition, students are required to take one or more of the following electives (totaling 8 credits): 


Earning a Certificate in Estate Planning with the LL.M. in Tax

Candidates for the LL.M. in Taxation can concurrently achieve a Certificate in Estate Planning. This option allows attorneys who wish to concentrate in estate planning the opportunity to receive the additional credential at little additional cost. 

Advanced Credit Toward the Degree 

Individuals may receive credit toward the LL.M. in Tax for certain courses taken in J.D. programs.

For students who began the LL.M. in Tax program prior to Fall 2022:

Under the combined J.D./LL.M. in Taxation program, graduates of the University of Baltimore J.D. program can receive advanced credit toward the LL.M. in Tax degree for up to 15 credits earned for tax courses taken in the J.D. program. To receive advanced LL.M. credit for a tax course (subject to the 15-credit cap), a student must (a) have received a grade of B or better for the course, and (b) enroll in the LL.M. in Tax program within three calendar years of receiving the J.D. degree. 

Graduates of J.D. or LL.B. programs other than the University of Baltimore can receive advanced credit toward the LL.M. in Tax degree for up to 15 credits of qualifying tax courses taken while enrolled in a J.D. program at an ABA-approved law school. Such courses must have content that is substantially similar to courses offered in the LL.M. in Tax program. To receive advanced LL.M. credit for a qualifying tax course (subject to the 15-credit cap), a student must have (a) received a grade of B or better for the course, and (b) taken the course within five calendar years of enrolling in the LL.M. in Tax program. 

For students who begin the LL.M. in Tax program in or after Fall 2022:

Under the combined J.D./LL.M. in Taxation program, graduates of the University of Baltimore J.D. program can receive advanced credit toward the LL.M. in Tax degree for up to 12 credits earned for tax courses taken in the J.D. program. To receive advanced LL.M. credit for a tax course (subject to the 12-credit cap), a student must (a) have received a grade of B or better for the course, and (b) enroll in the LL.M. in Tax program within three calendar years of receiving the J.D. degree. 

Graduates of J.D. or LL.B. programs other than the University of Baltimore can receive advanced credit toward the LL.M. in Tax degree for up to 12 credits of qualifying tax courses taken while enrolled in a J.D. program at an ABA-approved law school. Such courses must have content that is substantially similar to courses offered in the LL.M. in Tax program. To receive advanced LL.M. credit for a qualifying tax course (subject to the 12-credit cap), a student must have (a) received a grade of B or better for the course, and (b) taken the course within five calendar years of enrolling in the LL.M. in Tax program. 

Course Descriptions

Required Courses

 

Basic concepts in federal income taxation, including gross income, exclusions, adjusted gross income, deductions, exemptions, credits, assignment of income, identification of the taxpayer, tax rates, depreciation, and the alternative minimum tax.

*Fundamentals of Federal Income Tax I is a prerequisite for all other tax courses except Tax Research and Writing. (In the fall semester only, Fundamentals of Federal Income Tax I is a prerequisite or co-requisite for Tax Research and Writing.)  Fundamentals of Federal Income Taxation I typically is offered fall semester only. Students who do not begin their course work in the fall semester may take courses during spring and summer terms without meeting this prerequisite requirement, with the approval of the program director. Students must take Fundamentals of Federal Income Tax I at the earliest opportunity. Completing Tax Research and Writing, as well as Fundamentals of Federal Income Tax II, early in the program is recommended highly.

Federal income taxation of corporations and their shareholders with emphasis on the formation of the corporation, capital structure, operational alternatives, distributions, partial and complete liquidations, personal holding companies, and the accumulated earnings tax. Formation, operation, and liquidation of S-corporations also are covered..

Continuation of basic tax concepts including cash and accrual methods, capital gains and losses, 1231 transactions, recapture, original issue discount and imputed interest, below-market loans, installment sales, like-kind exchanges, involuntary conversions, the at-risk rules, and passive loss rules.

Problems encountered in the formation, operation, and liquidation of a partnership including the acquisition of partnership interests, compensation of the service partner, the treatment of partnership distributions, and problems associated with the disposition of partnership interests or property by sale.

Study of the evolution and structure of the federal income tax system from a public policy perspective with a focus on legal, economic, social, and practical considerations. Alternatives, including current legislative proposals, are considered. Students prepare a paper on a tax policy issue approved by the professor.

Aspects of practice before the Internal Revenue Service, including ruling requests, handling of audits, assessment of deficiencies and penalties, closing agreements, tax liens, statutes of limitations, claims for refunds, appeals conferences, and practice before the U.S. Tax Court, U.S. district courts, Claims Court, and appellate courts. Also includes an analysis of the problems encountered in parallel civil and criminal proceedings, problems involving government investigatory powers, and taxpayer rights and privileges.

Research and writing projects on federal tax subjects with analysis and instruction in tax research techniques, materials, and methodology. Students prepare legal memoranda.

*Fundamentals of Federal Income Tax I is a prerequisite for all other tax courses except Tax Research and Writing. (In the fall semester only, Fundamentals of Federal Income Tax I is a prerequisite or co-requisite for Tax Research and Writing.) Fundamentals of Federal Income Taxation I typically is offered fall semester only. Students who do not begin their course work during the fall semester may take courses during spring and summer terms without meeting this prerequisite requirement, with the approval of the program director. Students must take Fundamentals of Federal Income Tax I at the earliest opportunity.  

Electives:

An analysis of FASB ASC 740 Income Taxes. Such analysis will include the standards of financial accounting and reporting for income taxes that result from a company’s activities during the current and preceding year. The course will analyze income taxes that are currently payable under the respective income tax statutes as well as the tax consequences of those items that are deferred for federal income tax purposes but included for financial reporting purposes.  Additional Prerequisite: Fundamentals of Federal Income Tax II

 

Analysis of the effect of income taxes on real estate transactions; a comparison of the various entities used for the ownership and development of real estate; real estate syndications, and basis adjustments; alternative financing techniques such as the sale-leaseback; depreciation, amortization, and obsolescence; passive activity and at-risk rules; and REITS. Additional prerequisite: Fundamentals of Federal Income Taxation II.
Under the supervision of a practicing attorney and faculty supervisor, students learn about the lawyering process firsthand by interning in the private or public sector and attending a classroom component. Students develop reflective learning and problem-solving skills, increase their substantive legal knowledge, explore issues of professionalism and ethics, and gain a deeper understanding of the legal system and the practice of law. Students may register for a three-credit internship and must have their field placement approved by the Director of Externships and the Director of the Graduate Tax Program. This program has special rules with respect to who may register and what requirements must be satisfied to earn credits under this program. [Admission by permission of the Director of the Graduate Tax Program only]
An introduction to the basics of bankruptcy law and creditors' rights and analysis of tax issues that arise.
Business valuation arises in mergers, acquisitions, divestitures, estate taxation, lost profits litigation, buy-out agreements, commercial lending, venture capital, IPOs and other exit strategies. This course addresses valuation modeling, using asset pricing theory and practice and employing advanced applications such as EXCEL and corporate databases. The course material is of interest to students who envision careers as CPAs, business valuation experts, corporate finance analysts and investment bankers. Prerequisite: FIN 605 or instructor permission.
An integrated study of the impact of tax, securities, corporate law, and partnership law on business transactions. Topics include a selection of the form of business enterprise, acquisitions and dispositions of business interests, and professional responsibility issues. Students prepare writing projects relating to the course material. Additional prerequisites: Corporate Taxation; Partnership Taxation.
Analysis of the techniques used by multiple, related corporations to report income and losses. Detailed examination of the consolidated income tax regulations and consideration of other problems encountered by affiliated groups of corporations. Additional prerequisite: Corporate Taxation.
Under the supervision of an in-house counsel and faculty supervisor, students learn about the lawyering process firsthand by externing in a corporate law office and attending a class. Students develop reflective learning and problem-solving skills, increase their substantive legal knowledge, explore issues of professionalism and ethics and gain a deeper understanding of the legal system and the practice of law. This program has special rules with respect to who may register and what requirements must be satisfied to earn credits under this program. Students must have their field placement approved by the Director of Externships and the Director of the Graduate Tax Program. [Admission by permission of the Director of the Graduate Tax Program only]
Analysis of the tax treatment of corporations and shareholders in corporate acquisitions, divisions, reincorporations, and recapitalizations, including a discussion of section 338 and the net operating loss carryover rules. Additional prerequisite: Corporate Taxation.
Basic principles of federal estate and gift taxation, including computation of the taxable estate, inter vivos transfers, transfers in contemplation of death, transfers with retained interests or powers, joint interests, life insurance proceeds, property subject to powers of appointment, the marital deduction, and the unified credit.
Methods of disposing of estates by will, life insurance, inter vivos arrangements, and consideration of resulting tax and administrative problems. The course also focuses on gathering and analyzing facts in the planning and drafting of trusts, wills, and related documents. Additional prerequisite: Estate and Gift Taxation.
Methods of providing tax-free and tax-deferred compensation to employees, including section 83 tax planning, stock options tax planning, incentive compensation arrangements, and methods of funding nonqualified plans.
A workshop course that examines the process of formulating and enacting federal tax legislation, as well as areas ripe for current federal tax legislative proposals; these areas may include income tax rates, capital gains taxation, tax expenditures, and the federal estate tax.  Students will engage in drafting and other exercises that simulate the process of creating such legislation from the standpoint of staffers on Congressional committees.
Analysis of the federal income tax provisions applying to US inbound and outbound transactions and investments. The course covers US resident status, source-of-income rules, graduated tax on effectively connected income, withholding tax on FDAP income, branch profits tax, FIRPTA, tax treaties, foreign tax credit, foreign earned income exclusion, subpart F, and transfer pricing.
Federal income taxation of decedents' estates, simple and complex trusts, charitable trusts, and grantor trusts. The course covers the preparation of fiduciary income tax returns with emphasis on unique tax issues such as income in respect of a decedent, distributable net income, and fiduciary accounting.
Students may study an area of particular interest to them, not covered in a significant way elsewhere in the program, via an independent study. To qualify, students must submit a written proposal and obtain the consent of a faculty member who supervises the project. The proposal must be approved by the supervising faculty member and the program director.
This course examines the life cycle of a criminal tax case, including the warning signs that a civil tax case may be referred for criminal investigation, applicable privileges, potential defenses, the opening of an administrative investigation, sources of information, authorization of a grand jury investigation and prosecution, best practices in plea negotiations, trial strategies, sentencing, and collateral and civil tax consequences.  The course also will address the current priorities of IRS Criminal Investigation and the Department of Justice, and cases pulled from the headlines. Prerequisite: Federal Income Tax or Fundamental of Federal Income Tax I. Tax Practice and Procedure is recommended.
Under the supervision of a supervising judge and a faculty supervisor, students learn about the lawyering and judicial processes firsthand by interning at the court and attending a classroom component. Students develop reflective learning and problem-solving skills, increase their substantive legal knowledge, explore issues of professionalism and ethics, and gain a deeper understanding of the legal system, judicial decision making, and the practice of law. Students may register for a three-credit internship and must have their field placement approved by the Director of Externships and the Director of the Graduate Tax Program. This program has special rules with respect to who may register and what requirements must be satisfied to earn credit under this program. [Admission by permission of the Director of the Graduate Tax Program only]
This course will begin with a brief overview of the U.S. and State constitutional constraints on state taxation, including a review of the significant U.S. Supreme Court decisions interpreting those limitations. The course will then explore Maryland’s various taxes, with a particular focus on its personal income tax, corporate and pass-through-entity taxes, sales/use tax, and real and personal property taxes. Other Maryland taxes will be discussed briefly. In addition, this course will cover Maryland tax procedure, including how liabilities are calculated, types and methods of assessment, and the dispute and appeal process.
An introduction to pension and profit-sharing law with particular emphasis on Title 2 (IRS) of ERISA. The course is geared toward understanding all of the pension and profit-sharing rules that must be met for plan qualification, with emphasis on qualified plan planning for both incorporated and unincorporated forms of business.
This course will explore federal and state constitutional and statutory limitations on state authority to tax individuals and business entities, including those that conduct multistate and multinational businesses.  Featured topics will include the Due Process Clause of the U.S. Constitution, taxation of individuals and business entities, sales and use tax nexus, and PL 86-272 limitations on state income taxation.  In addition, the course will cover general sales and use tax (SUT) principles, apportionment of income derived from a multistate business, combined versus separate entity reporting, and state property taxes.  Maryland's broad array of state and local taxes also will be examined briefly.
Under the supervision of a practicing attorney and faculty supervisor, students learn about the lawyering process firsthand by interning at a public interest agency and attending a classroom component. UB Law Externship program will assist students in finding externships at partner agencies. Students must have their field placement approved by the Director of Externships and the Director of the Graduate Tax Program. Students will develop reflective learning and problem-solving skills, increase their substantive legal knowledge of issues affecting public interest lawyers, explore issues of professionalism and ethics, and gain a deeper understanding of the legal challenges facing low-income people and other vulnerable populations. [Admission by permission of the Director of the Graduate Tax Program only]
Federal income taxation of S-corporations and their shareholders with emphasis on the creation of the S-corporation, capital structure, operational alternatives, distributions, and liquidations.
Students represent low-income taxpayers involved in matters with the Internal Revenue Service. Under the supervision of a faculty member, students interview clients, research substantive and procedural law, and represent clients before the IRS and the U.S. Tax Court. The course includes a weekly seminar and supervision meetings in addition to casework. Additional prerequisite: Evidence; Professional Responsibility.  Recommended: Interviewing, Negotiating, and Counseling; Tax Practice and Procedure. [Admission by permission only]
Analysis of provisions relating to the qualification for exemption from federal income tax, with emphasis on section 501(c)(3) organizations, private foundations, and the treatment of unrelated business income.

Research and writing projects on federal tax subjects with analysis and instruction in tax research techniques, materials, and methodology. Students prepare legal memoranda.

*Fundamentals of Federal Income Tax I is a prerequisite for all other tax courses except Tax Research and Writing. (In the fall semester only, Fundamentals of Federal Income Tax I is a prerequisite or co-requisite for Tax Research and Writing.) Fundamentals of Federal Income Taxation I typically is offered fall semester only. Students who do not begin their course work during the fall semester may take courses during spring and summer terms without meeting this prerequisite requirement, with the approval of the program director. Students must take Fundamentals of Federal Income Tax I at the earliest opportunity.  

Welfare benefit plans are employer-sponsored plans that provide employees with benefits other than pension and retirement plans and deferred compensation. Welfare benefit plans include life insurance, health insurance, disability insurance, vacation pay, severance pay, educational reimbursement, group legal services, and dependent assistance care plans. The course focuses on federal income tax requirements for various welfare benefit plans, including fringe benefits and health care continuation coverage under COBRA. Examination of the income tax consequences to employers who sponsor, and employees who participate in, welfare benefit plans. Discussion of the various mechanisms for offering welfare benefit plans, such as cafeteria plans under section 125 and VEBAs under section 501(c)(9).