Overview
This degree program is ideal for students who expect international tax law to play an important role in their professional careers, have a solid foundation in their own domestic tax system, and have enough experience to bring their own questions to the program.
Specifically, the degree benefits foreign attorneys who:
- Are practicing, or intend to practice, in or with Latin America in order to develop the niche market of structuring investments in and by Latin America.
- Are ready to delve into a more sophisticated tax practice and looking to understand enough U.S. tax law to work well with U.S. tax lawyers.
The LL.M Degree is 28 course credits, some required and some elective, and students are also required to take a course introducing them to the U.S. legal system.
Admission Requirements
The Taxation of Cross-Border Investment LL.M. Program is for foreign lawyers. We are prepared to work with students from diverse legal system backgrounds to facilitate a successful transition to studying law in the United States.
• International applicants must hold a J.D. degree or its equivalent from a foreign institution.
• Applicants whose native language is not English must take the Test of English as a Foreign Language (TOEFL). A score of 580 on the written, 237 on the computer based or 92 on the internet based TOEFL test is required to be considered for admission. The minimum required IELTS score for admission is 7.0.
• Applicants must have an official TOEFL score report sent to the Graduate Program in Taxation from the Educational Testing Service (ETS)—School Code 5815, Department Code 03.
Curriculum Requirements
| Code | Title | Credit Hours |
|---|---|---|
| Required Courses | 16 -9 | |
| TAX 140 | Taxation of Business Entities | 2-3 |
| or TAX 905 | Corporate Tax I | |
| or TAX 948 | Corporate Tax | |
| or TAX 950 | Partnership Tax | |
| TAX 915 | International Inbound | 2 |
| TAX 916 | International: Outbound | 2 |
| LAW 105 | Federal Income Tax I | 4 |
| TAX 946 | Federal Wealth Transfer Tax | 2 |
| TAX 949 | Property Transactions | 1-2 |
| TAX 973 | Income Tax Treaties | 1 |
| LAW 999 | Introduction to U.S. Law | 2 |
| Elective Courses 1 | 9-12 | |
| Introduction to U.S. International Policy | ||
| U.S. Tax Policy: Current Topics | ||
| Income Tax of Trusts and Estates | ||
| Representing High Net Worth Individuals | ||
| International Trans Europe | ||
| Taxation of Athletes and Entertainers | ||
| Taxation of Global Shipping Operations | ||
| Tax Issues Relating to Cryptocurrency and Blockchain | ||
| International Transactions Latin America | ||
| Investing in Sports: Private Equity and Emerging Industry Trends | ||
| The Digital Economy and International Taxation - National and International Responses | ||
| Federal Tax Procedure | ||
| Federal Criminal Tax Practice | ||
| Estate Planning | ||
| Tax Accounting | ||
| Introduction to Financial Instruments | ||
| Corporate Tax II | ||
| Partnership and Property II | ||
| Advanced Intl Tax Planning | ||
| Advanced Individual Tax Issues: Families and Lower Income Taxpayers | ||
| Tax Issues relating to Movement of Foreign Tech Founders into Miami in the 21st Century | ||
| Tax Policy | ||
| Tax Research and Writing | ||
| Total Credit Hours | 28 | |
1 Not all elective courses may be offered every year.
This is a sample Plan of Study. Your actual course sequence may vary depending on your previous academic experience as well as current course offerings. Students should meet with their academic advisor each semester to determine the appropriate course selection.
Sample Plan of Study
1-Year Program
| Year One | ||
|---|---|---|
| Summer | Credit Hours | |
| LAW 105 | Federal Income Tax I | 4 |
| Credit Hours | 4 | |
| Year Two | ||
| Fall | ||
| TAX 905 | Corporate Tax I | 2 |
| TAX 915 | International Inbound | 2 |
| TAX 946 | Federal Wealth Transfer Tax | 2 |
| TAX 949 | Property Transactions | 1 |
| LL.M. Elective Credits | 5 | |
| Credit Hours | 12 | |
| Spring | ||
| TAX 916 | International: Outbound | 2 |
| TAX 973 | Income Tax Treaties | 1 |
| LL.M. Elective Credits | 9 | |
| TAX 140 | Taxation of Business Entities | 2-3 |
| Credit Hours | 14 | |
| Total Credit Hours | 30 | |
Mission
To foster the intellectual discipline and analytical skills that will prepare graduates of the Graduate Program in Taxation of Cross-Border Investment to develop cross-border investment structures that satisfy the business, tax, and legal demands of multiple jurisdictions.
To provide non-U.S. tax lawyers, particularly those from civil law countries, with an understanding of the intellectual framework for the U.S. practice of law in order to facilitate productive future interactions and collaborations with U.S. tax lawyers.
To provide to non-U.S. tax lawyers an introduction to the U.S. legal and tax system that will allow them to develop a more sophisticated cross-border practice in their home countries
In fulfilling this mission, the Graduate Tax Program is committed to supporting students as they develop an advanced substantive knowledge of international tax law, cross-border investment structures, and the professional responsibilities of international tax lawyers.
Student Learning Outcomes
- Students will demonstrate an ability to engage in complex and creative legal reasoning within the context of the U.S. common law system and to produce legal writing that bridges differences between legal systems.
- Students will demonstrate an understanding of the U.S. tax rules that affect cross-border tax planning.
- Students will demonstrate a facility with cross-border tax planning techniques that take into account the business, tax, and legal demands of multiple jurisdictions.
