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LL4CK      Half Unit
Taxation of Corporate Transactions

This information is for the 2019/20 session.

Teacher responsible

Dr Ian Roxan NAB 7.25

and others.

Availability

This course is available on the LLM (extended part-time), LLM (full-time), MSc in Law and Accounting and University of Pennsylvania Law School LLM Visiting Students. This course is available with permission as an outside option to students on other programmes where regulations permit.

This course will be relevant to the following LLM specialisms: Corporate and/or Commercial Law; International Business Law; Taxation.

This course is capped at 30 students. Students must apply through Graduate Course Choice on ÐÓ°ÉÂÛ̳forYou.

Pre-requisites

Students must have completed Comparative Corporate Taxation (LL4CJ).

Students must have completed Comparative Corporate Taxation (LL4CJ) or have permission of the course convenor.

Students should be familiar with the UK tax system, or have working knowledge of another system of business taxation. Otherwise, students should take LL4Z1 Business Taxation beforehand.

Course content

The course examines the principles governing the taxation of corporate and other business transactions. The course will take a comparative approach to examining the business tax systems of the United Kingdom and other countries. The main tax system studied will be that of the United Kingdom (primarily corporation tax together with income tax and capital gains tax), but the tax system of the United States will also be examined and typically that of Germany or another country as well. Continuing on from the topics studied in LL4CJ, this course will look in-depth at a number of key advanced topics that are central to corporate taxation, such as the treatment of shares, the taxation of corporate finance, the treatment of groups of companies, and the taxation of corporate reorganisations (broadly defined).

Teaching

20 hours of lectures in the LT. 2 hours of lectures in the ST.

10 weekly two-hour seminars in the Lent Term, including seminars led by national tax experts. 2 hours of seminars in the ST.

There will be a reading week in Week 6 of the LT.

Formative coursework

Students are expected to submit a group assignment on a major part of the course, with the option of submitting a 2,000-word formative essay, or to submit an equivalent assignment during the course.

Indicative reading

Ault et al, Comparative Income Taxation: A Structural Analysis (Kluwer, 3rd ed. Rev, 2010); Harris, Corporate Tax Law: Structure, Policy and Practice, (Cambridge Univ. Press, 2013); Gordon and Montes Manzano, Tiley & Collison's U.K. Tax Guide (current edition); Loutzenhiser, Tiley’s Revenue Law (Hart, 8th ed., 2016); Bramwell et al., Taxation of Companies and Company Reconstructions; Eustice & Brantley (formerly Bittker and Eustice), Federal Income Taxation of Corporations and Shareholders; Abrams & Doernberg, Essentials of US Taxation; Tolley's Yellow Tax Handbook, or CCH The Red Book (current edition).

Detailed reading lists will be provided during the course via Moodle.

Recommended preliminary reading

Hugh Ault et al, Comparative Income Taxation (Kluwer Law International 3rd ed. 2010).

Assessment

Exam (100%, duration: 2 hours, reading time: 15 minutes) in the summer exam period.

An OPEN BOOK examination. Candidates will be permitted to take into the examination room any written material they wish.

Key facts

Department: Law

Total students 2018/19: 12

Average class size 2018/19: 12

Controlled access 2018/19: No

Value: Half Unit

Personal development skills

  • Team working
  • Communication
  • Specialist skills