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.
•    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

Required Courses
TAX 140Taxation of Business Entities2
TAX 915International Inbound2
TAX 916International: Outbound2
TAX 925Introduction to U.S. Tax System3
TAX 946Federal Wealth Transfer Tax2
TAX 949Property Transactions1
TAX 973Income Tax Treaties1-2
TAX 999Introduction to US Law (LLM)2
Elective Courses 112-13
Introduction to U.S. International Policy
U.S. Tax Policy: Current Topics
Income Tax of Trusts and Estates
High Net Worth
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: From Athletes Venture Capital to Private Equity and Spacs
New International Tax Consensus: OECD's "Pillar One" and "Pillar Two" Proposals
Federal Tax Procedure
Federal Criminal Tax Practice
Estate Planning
Tax Accounting
Introduction to Financial Instruments
Total Credit Hours28

 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

Plan of Study Grid
Year One
FallCredit Hours
TAX 140 Taxation of Business Entities 3
TAX 915 International Inbound 2
TAX 916 International: Outbound 2
TAX 946 Federal Wealth Transfer Tax 2
LL.M. Elective Credits 6
 Credit Hours15
Spring
TAX 925 Introduction to U.S. Tax System 4
TAX 949 Property Transactions 1
TAX 973 Income Tax Treaties 2
TAX 999 Introduction to US Law (LLM) 2
LL.M. Elective Credits 4
 Credit Hours13
 Total Credit Hours28

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

  1. 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.
  2. Students will demonstrate an understanding of the U.S. tax rules that affect cross-border tax planning.
  3. Students will demonstrate a facility with cross-border tax planning techniques that take into account the business, tax, and legal demands of multiple jurisdictions.