Tax Law Fundamentals for Attorneys

Rare are the transactions, lawsuits and events involving money in today’s society that do not have tax ramifications of one sort or another. For lawyers involved in negotiating any kind of agreement or seeking monetary relief of any kind (whether to pay or be relieved of a claimed obligation) it is essential to consider the tax implications of the alternatives for any decision or outcome.

The economic and legal structure of transactions and the evidence thereof have portentous meaning for the proper tax treatment and for the unintended consequences that may result if tax authorities challenge or recharacterize any in the course of audit or otherwise.

Understanding the fundamental principles that define the context for the consideration of the tax treatment is the goal of this course. Without such understanding, it is altogether possible that assumptions may be misplaced; with such understanding we, as lawyers, can have greater confidence that the strategies we adopt and the advice we provide to clients is grounded in accurate appreciation of the attendant tax benefits and burdens.

Learning Objectives:

I.   Explanation of bedrock tax law principles.

II.  Understanding of governing Internal Revenue Code provisions.

III. Conceptual framework for evaluating tax incidents.

IV. Basic Knowledge of evidentiary standards for tax contests.

Program Director: Sigalle Barness