UNIVERSITY OF HAWAII AT MANOA
ADVANCED CORPORATE TAXATION
2003 SUMMER SESSION – TERM 2
COURSE MEETS: Monday and Wednesdays, 6:00 p.m. - 9:30 p.m., BusAd D-104
July 7, 2003 through August 13, 2003
INSTRUCTORS: Kurt Kawafuchi, J.D., C.P.A., Masters of Laws in Taxation
Lisa Lo, Masters of Accounting, C.P.A.
OFFICE HOURS: Available immediately after class or e-mail Kurt at
“firstname.lastname@example.org,” or call 587-1513 (Office) or 258-3383
(Cell.) to schedule an appointment, or email Lisa Lo at
TEXTS: (1) Federal Income Taxation of Corporations and Sharholders (7th
Edition). Authors: Boris I. Bittker and James S. Eustice, Warren
Gorham & Lamont (2000 Edition) (Text"); (2) Federal Income
Taxation of Corporations and Sharholders_2002 Cumulative
Supplement and Student Edition (Supplement"); and (3) Federal
Income Taxation of Corporations and Sharholders_Study
(Optional) West's INTERNAL REVENUE CODE OF 1986 AND
TREASURY REGULATIONS: ANNOTATED AND SELECTED
(2003 Edition) by James E. Smith, or comparable access to Internal
Revenue Code and Treasury Regulations.
COURSE The purpose of this course is to provide students with an overview and
OBJECTIVES: examination of selected advanced corporate taxation topics including
partial liquidations, IRC Section 304, complete liquidations, IRC
Section 338 elections, consolidated tax returns, tax-exempt
organizations, and advanced corporate reorganization topics including
special issues problems, tax attributes, and foreign corporate
reorganizations-IRC Section 367. This course emphasizes the
development of the student's critical analysis through problems and oral
presentations of the solutions.
Attendance, Assignments, 30%
Mid-Term Examination 35%
Final Examination 35%
(1) Attendance, Assignments, and Participation. Attendance, assignments, and class
participation will comprise 30% of each student's grade. Students are expected to attend class,
be prepared for class, and participate in class discussions and activities. Each student shall
prepare written solutions to the assigned homework problems that will be turned in each class.
Each student is entitled to one “pass” during the semester, which can be utilized when the
student is scheduled to make his or her presentation, or for any other class. For the “pass,” the
student will be treated as if the student turned in a “credit” homework assignment. Written
solutions will be graded, “Credit”, “Late” (1/2 credit), or “No Credit”. Every week, each
homework problem for the following week will be assigned to one student to present the
solution to his or her assigned problem for the following week.
(2) Mid-Term Examination. The Mid-Term Examination comprises 35% of each
student's grade. It is tentatively scheduled to be ninety (90) minutes on Monday, July 28,
2003. The Midterm Examination is most likely to contain short answer, computational, and
one or more problem-solving and essay questions. The Mid-Term Examination is open book
(3) Final Examination. The Final Examination comprises 35% of each student's
grade. It will generally emphasize the materials and topics after the Mid-Term Examination.
It is scheduled to be ninety (90) minutes on Wednesday, August 13, 2003. The Final
Examination is most likely to contain short answer, computational, and one or more
problem-solving and essay questions. The Final Examination is open book and notes.
July 7 Introduction and Review of U.S. Income Taxation of
July 9 Text: Partial Liquidations, 9.07, and Redemptions by Affiliated
Corporations: IRC Section 304, 9.09
July 14 Text: Complete Liquidations: 10.00-10.05,  and ,
10.06 –10.08, Subsidiary Liquidations: 10.20-10.21[a]-[c],
10.21-10.24; Taxable Acquisitions: 10.40-10.43 (Including
IRC Section 338)
July 16 Text: Consolidated Tax Returns: 13.40-13.42
July 21 Text: Consolidated Tax Returns: 13.43-13.45
July 23 Text: Consolidated Tax Returns: 13.46-13.48
July 28 MID-TERM EXAMINATION; Overview of Tax-Free
Corporate Reorganizations: A-G and Triangular Tax-Free
July 30 Text: Corporate Divisions: 11.02-11.11; Treatment of Parties to
August 4 Text: Corporate Tax Attributes: 14.01, 14.20, 14.21, 14.40-
14.41[c], 14.41[a], 14.41[a], 14.41, 14.42-14.43,
14.44[a]-[c], 14.44-, ][a], , 14.45-14.45.
August 6 Text: Organization, Liquidation, and Reorganization of Foreign
Corporations: IRC Section 367 and Related Provisions:
August 11 Tax-Exempt Organizations including nonprofit corporations
August 13 FINAL EXAMINATION
* - Readings including the readings in the Supplement.