The federal income tax laws touch the lives of every attorney and his or her clients. Whether you become a litigator, a transactional attorney, a general practitioner, an in-house counsel, or some other type of attorney, the advice you give your clients may have federal tax consequences (whether you are aware of them or not).
The purpose of this course is to give you a general understanding of the basic structure and concepts of the federal income tax laws. The basic questions we will address are:
- What is subject to tax – this involves the threshold question of “what is gross income,” and also examines what amounts are deductible,excludible, or otherwise not subject to tax
- When is income subject to tax – this inquiry focuses on the concept of “realization”; the timing of taxation is almost as important as whether something us subject to tax, and attempts to delay the inclusion of income in the tax base (or attempts to accelerate deductions) play an important role in tax planning
- Who is taxed – this involves attribution of income to particular taxpayers
- How is income taxed – this focuses on the more favorable treatment accorded certain types of income (e.g., capital gains)
After examining these topics you should be able to recognize basic tax issues that arise in practice (as well as in your personal life), and have a general understanding of how to resolve them.