Problems of Timing
This course addresses an important aspect of tax planning relating to the timing of income and deductions. Topics covered include tax accounting methods and supporting doctrines such as cash equivalency, constructive receipt, and economic benefit; inventories; inter-company pricing issues; installment sales and long-term contracts; at risk rules and passive activity losses; imputed income and OID; and incentive stock options and other nonqualified deferred compensation topics. The course presents issues from both a technical viewpoint and from the perspective of tax policy. Open to LL.M. students only.