LLM 363

Taxation of Financial Instruments

3 Unit(s)

Examines the tax aspects of financial instruments, products, and transactions. Covers basic principles, including financial terminology, types of market participants, as well as the tax concepts of timing, character, and source. Addresses wash sales, constructive sales, short sale rules, straddles, market discount, original issue discount, Section 1256 and notional principal contract regulations. The course will be divided into three broad categories: Equity, Debt and Derivatives. Students will study the detailed rules regarding the tax treatment of financial instruments including stocks, bonds, options, forward contracts, futures contracts, convertible and contingent payment instruments, swaps and hybrid instruments. Cross-listed with and equivalent to TA 363. (JD students seeking to enroll must obtain the approval of the program director.) Prerequisite: LLM 317A and LLM 330.