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Title: Graduate tax program
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Title: Graduate tax program
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Language: English
Creator: Fredric G. Levin College of Law, University of Florida
Publisher: Fredric G. Levin College of Law, University of Florida
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Copyright Date: 2009
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Table of Contents
    Front Cover
        Front Cover
    Foreword
        Foreword
    Main
        Page 1
        Page 2
        Page 3
        Page 4
        Page 5
        Page 6
        Page 7
        Page 8
        Page 9
        Page 10
        Page 11
        Page 12
        Page 13
        Page 14
        Page 15
        Page 16
        Page 17
        Page 18
        Page 19
        Page 20
        Page 21
    Back Cover
        Back Cover
Full Text











FREDRIC G. LEVIN COLLEGE OF LAW















THE UNIVERSITY OF FLORIDA GRADUATE TAX PROGRAM is

recognized as one of the country's premier tax programs, offering the LL.M.

in Taxation, the LL.M. in International Taxation and the S.J.D. in Taxation.

The renowned faculty, the academic ability and diversity of the student body,

and the Richard B. Stephens Tax Research Center contribute to that reputa-

tion and are important factors for prospective tax candidates to consider.



Faculty members are committed to full-time teaching, are authors of some of

the most widely used textbooks and treatises, and have extensive professional

experience. Students come from all over the U.S. and a number of foreign

countries. They have strong academic records, and many have had law

practice or other work experience before entering the program. The quality

of our faculty and students, and the interaction that takes place on a full-time

basis, result in a truly unique experience.



In addition, for most students the cost of attending the Graduate Tax

Program, including tuition and living expenses, is significantly lower than

that of other programs. A number of students in the program also receive financial

assistance.



We appreciate your interest and welcome your application.


Michael K. Friel
Director, Graduate Tax Program
Professor of Law








www.law.ufl.edu/tax
















Tax Law at Florida


That assessment by one of our graduates is shared by
lawyers across the United States who chose Florida
for their advanced tax studies. The study of tax law is
indeed a challenging undertaking. Tax issues not only
are important and pervasive in today's world, they
are increasingly complex and constantly changing.
Tax law careers are equally challenging, but generally
very satisfying and rewarding. And skilled lawyers
are in demand.

For more than 30 years, the University of Florida
Graduate Tax Program has helped prepare students for


careers in tax law. Today, the program is widely rec-
ognized by tax scholars and practitioners nationwide as
one of the nation's best. The LL.M. in Taxation degree
and the LL.M. in International Taxation degree involve
a one-year course of study and are designed for full-time
degree candidates, with classes held during the day. The
Doctor of Juridical Science (S.J.D.) in Taxation degree
requires a three-to-five year program of classes and
extensive research and writing.

Graduate Tax Program courses are taught almost
exclusively by full-time members of the tax faculty,
who bring to the classroom dedication to teaching
and scholarly research, along with significant practice
experience. They have published taxation textbooks
and treatises used at law schools and in tax practice
nationwide. A unique feature of Florida's program is
the close working relationship between faculty and
students.

The program attracts outstanding students from
all parts of the country who have satisfied the pro-
gram's admissions standards. The student body
and reputation of the Graduate Tax Program attract
employers from throughout the United States and
abroad. Graduates have been employed in every state
in the nation by law firms, accounting firms, indus-
try and government, and a number teach at U.S. law
schools.

Florida Graduate Tax students study a broad range of
topics, and also may concentrate on particular interests,
debate major issues of tax policy, and study the fine
details of recent tax legislation. They attend workshops
and lectures by leading practitioners, government offi-
cials and academics, and take advantage of a strong
alumni network.


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LL.M. in Taxation
LL.M. in Taxation


DEGREE REQUIREMENTS
The Master of Laws in Taxation is awarded
upon satisfactory completion of at least
26 semester credit hours. Courses for
the degree are designed to be completed
in two semesters and a summer term.
(Students considering completing the
program over a different period of time
should consult the director prior to start-
ing.) Typically, a student enrolls in four
or five Graduate Tax courses in fall and
spring terms, and one or two courses in
the summer. Federal Tax Research is a
required course, consisting of lectures by
tax faculty and invited guest speakers and
culminating in the writing of a tax research
paper.

Ordinarily, all coursework for the LL.M. in
Taxation degree will consist of Graduate
Tax courses. Permission to take a J.D.
course for LL.M. credit is subject to the
discretion of the director. A grade of
B or better must be earned in the J.D.
course to receive LL.M. credit, but the


grade is not computed in determining
the Graduate Tax Program grade point
average. No more than four credits of the
26 required to graduate may be earned
through J.D. level courses, Independent
Study (LAW 7905) or Supervised
Research (LAW 7910), all of which require
the prior approval of the director. A
cumulative 3.0 GPA (4.0 scale) is required
for graduation. Students failing to main-
tain that average over two semesters
must petition for permission to continue.


CONCENTRATION OPPORTUNITIES
An essential part of preparation for tax
practice involves in-depth study of a
wide range of laws and policies, and
the Graduate Tax Program provides that
breadth of study. For LL.M. in Taxation stu-
dents who wish to concentrate a portion of
their studies in a particular area of tax law,
the possibilities include:


Estate Planning
Courses may include:
* Taxation of Gratuitous Transfers
* Estate Planning
* Income Taxation of Trusts and
Estates
* Estate and Gift Tax Seminar

International Taxation
Courses may include:
* U.S. International Tax I
* U.S. International Tax II
* Comparative Taxation
* International Tax Seminar

Corporate/Business Taxation
Courses may include:
* Corporate Taxation I
* Corporate Taxation II
* Partnership Taxation
* Business Taxation Seminar


UF LAW GRADUATE TAX 3







































LL.M. in International Taxation


The LL.M. in International Taxation is
designed as a challenging and rewarding
program for full-time students that will
help prepare them for careers in interna-
tional tax law. The degree builds on the
strength of the LL.M. in Taxation, which
has drawn students from all 50 states and,
in recent years, from over 20 countries as
well, and which has established an inter-
national reputation for its high quality. The
new LL.M. in International Taxation places
the Graduate Tax Program in the forefront
in the study of international taxation.

DEGREE REQUIREMENTS
The LL.M. in International Taxation is
awarded upon satisfactory completion of
at least 26 semester credit hours, 13 or
more of which must be in international
tax courses. The degree is intended to be
completed in two semesters and a sum-
mer term, with a student ordinarily enroll-
ing in four or five courses in the fall and
spring terms, and one or two courses in
the summer term. Course loads of
students in the International Taxation
Program are subject to approval by the
director of the Graduate Tax Program.

The LL.M. in International Taxation is open
to both U.S. and international students.
Enrollment is not expected to exceed
25 students. Applicants who hold a J.D.
degree or its equivalent from a U.S.
law school must complete the required
research course and paper for the LL.M. in


Taxation degree, in addition to satisfying
the requirement to complete 13 or more
credit hours in international tax courses.
Applicants who hold a law degree from
a foreign university, and do not hold the
U.S. J.D. degree or its equivalent, must
complete the required research course
and paper, and LL.M. Taxation of Property
Transactions, in addition to satisfying
the requirement to complete 13 or more
credit hours in international tax courses.
A cumulative 3.0 grade point average is
required for graduation. Students failing to
maintain that average over two semesters
must petition for permission to continue.

FACULTY AND CURRICULUM
The faculty for the LL.M. in International
Taxation consists of the faculty of the
Graduate Tax Program (see page 11). The
curriculum for the LL.M. in International
Taxation includes all courses listed in the
Graduate Tax curriculum (see page 6).
Courses that constitute international tax
courses will include:
* U.S. International Tax I
* U.S. International Tax II
* International Tax Planning
* International Tax Policy
* Transfer Pricing
* Comparative Taxation
* Tax Treaties
* International Tax Seminar/Research
Students also will have the opportunity to
engage in approved Independent Study


projects under the supervision of a mem-
ber of the tax faculty.


FINANCIAL AID
Students in the LL.M. in International
Taxation program are eligible for Graduate
Tax Scholar awards (see page 18).

AID FOR LATIN AMERICAN STUDENTS
A limited number of scholarships are
available for students from Latin America
or the Caribbean. The scholarship pro-
vides a modest stipend for each term the
student is enrolled, but more significantly,
scholarship recipients are permitted to
pay Florida resident fees, rather than non-
resident semester credit hour fees.
A student must be a full-time student
and maintain an overall 3.0 or better
grade point average in order to retain
this scholarship.

LINKAGE INSTITUTES
The state of Florida has established link-
age institute programs for several coun-
tries and regions. A limited number of
well-qualified students who are citizens
of "linkage" countries are permitted to
pay resident rather than non-resident
tuition for a specified number of credit
hours. Programs currently exist for Brazil,
Canada, the Caribbean, China, Costa Rica,
Eastern Europe, France, Israel, Japan,
Mexico and West Africa.


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S.J.D. in Taxation


The University of Florida Levin College
of Law offers the nation's first Doctor of
Juridical Science (S.J.D.) in Taxation. The
degree is designed for those interested in
tax law teaching and/or scholarship, and
involves extensive study, research and
writing over a three-to-five year period.
The program admits a very limited number
of students based on their potential to con-
tribute to tax scholarship.

DEGREE REQUIREMENTS
A candidate for the S.J.D. in Taxation
degree must spend at least three semes-
ters in residence at the Levin College of


Law, and complete a program of study
consisting of a minimum of 30 credits of
graduate tax coursework.

The program ordinarily includes any
course required for the LL.M. in Taxation
degree and eight credits in writing semi-
nars and supervised research and writing.
In appropriate circumstances, courses
other than graduate tax courses may be
approved to be applied to the minimum
credit requirement.

A cumulative grade point average of at
least 3.5 on a 4.0 scale is required for


the degree, and failure to maintain this is
grounds for terminating a S.J.D. candidacy.

The S.J.D. degree is awarded only on suc-
cessful completion of a thesis, which may
consist of a single monograph or a series
of at least three major articles.

All requirements for the S.J.D. degree
must be completed within five years of the
beginning of the candidate's first semester
in residence as a S.J.D. candidate.


Florida Tax Review

The Florida Tax Review is an innovative law re

issues of tax law and policy.


Since its inception in 1993, the Florida Tax Review has become
one of the premier tax journals in the country. Articles are
faculty-selected and edited, and, in order to publish them on a
schedule more accelerated than that of many other law reviews,
each issue of the Review generally consists of a single article.

Articles published by the Review focus on a wide range of
timely and important tax topics. Recent issues, for example,
include articles on tax compliance; on tax rules governing
securities traders; on the taxation of personal injury awards;
on implementing formulary apportionment in international
taxation; on the tax treatment of a new employer's payment of
personal obligations of a new employee; on the use of tax incen-
tives in international taxation; and on constitutional limitations
on double taxation of the same income by more than one state.




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UF LAW GRADUATE TAX 5












Graduate Tax Curriculum

The Graduate Tax Program offers an outstanding curriculum to its students. The courses are taught almost exclusively by full-time members of the
tax faculty and the courses typically are restricted to Graduate Tax students.
The curriculum involves intensive study and preparation, and the full-time structure of the program enables students to work with each other and
consult their professors outside the classroom.


Taxation of Property Transactions
(3 Credits) Tax problems of individual taxpayers; problems inci-
dent to the sale, exchange, and other disposition of property,
including recognition and characterization concepts.

Timing Issues in Taxation
(2 Credits) Income tax accounting principles and problems; the
taxable year; accounting methods; delayed payment transactions;
time value of money.

Federal Tax Research Paper
(2 Credits) This is a required course, involving substantial
research and writing on a federal tax subject; lectures on vari-
ous topics; and instruction in tax research techniques. Seminars
are offered to satisfy this requirement.

Civil Tax Procedure
(2 Credits) Taxpayers' relationships with the Internal Revenue
Service, including reporting obligations, examination of returns,
conference and settlement procedures; deficiencies and their
assessment; tax court practice; limitation periods and their
mitigation; transferee liability; tax liens; and civil penalties.

Corporate Taxation I
(3 Credits) Tax considerations in corporate formations, distribu-
tions, redemptions and liquidations, including Subchapter C and
Subchapter S corporations. Consideration of alternatives relating
to the sales of corporate businesses.


Professor Patricia Dilley is former
staff director and chief counsel of
the Social Security Subcommittee
of the U.S. House Ways and
Means Committee.


Corporate Taxation II
(3 Credits) Prerequisite: Corporate Taxation I or Instructor's con-
sent. Corporate reorganizations; corporate acquisitions and divi-
sions, including transfer or inheritance of losses and other tax attri-
butes; corporate penalty taxes; consolidated returns provisions.

U.S. International Tax I
(3 Credits) Tax definition of resident; distinction between domestic
and foreign entities; taxation of business income and nonbusiness
income of foreign persons; taxation of income of trades or businesses
carried on by foreign persons in the U.S.; special rules on U.S. real
property interests; and branch profits and branch interest taxes.

U.S. International Tax II
(2 Credits) The foreign tax credit; special rules on controlled foreign
corporations; foreign currencies; and cross-border transfers in non-
recognition transactions. May be offered with additional coverage in
3-credit format.

Partnership Taxation
(3 Credits) Tax meaning of "partnership"; formation transactions
between partner and partnership; determination and treatment
of partnership income; sales or exchange of partnership inter-
est; distributions; retirement; death of a partner; drafting the
partnership agreement.

Federal Taxation of Gratuitous Transfers
(3 Credits) Federal estate, gift and generation-skipping transfer
taxes.

Income Taxation of Trusts E Estates
(2 Credits) Taxation of income of trusts and estates, including
simple and complex trusts, annuities, property distributions,
income in respect of a decedent, grantor trusts.

Estate Planning
(2 Credits) Planning lifetime and testamentary dispositions of
property; postmortem planning; analysis of small and large
estates; eliminating and offsetting complicating and adverse
factors; selection of a fiduciary and administrative provisions.

Deferred Compensation
(2 Credits) Tax consequences of compensation in forms other
than cash paid contemporaneously with performance of the ser-
vices. Includes non-qualified deferred compensation devices, and
qualified pension and profit-sharing plans. May be offered with
additional coverage in 3-credit format.

Tax Exempt Organizations
(2 Credits) A study of the exemption from federal income tax
accorded to a variety of public and private organizations, and the
tax treatment of contributions to such organizations; public policies
underlying exemption from tax and deductibility of contributions.


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Procedures in Tax Fraud Cases
(2 Credits) Criminal offenses and methods of proof; investigative
authority of the IRS; summons enforcement proceedings; search
warrants and grand jury subpoenas; constitutional defenses to the
compulsory production of evidence; attorney-client privilege, and
other objections available to taxpayers and third parties.

State E Local Taxation
(2 Credits) Nature and purpose of state taxation; comparison of
property and excise taxes; uniformity of taxation; assessment and
collection procedures; remedies available to taxpayers.

Consumption Taxation
(2 Credits) Value added taxes of various countries and other types
of consumption taxes, including personal consumption taxes and
the flat tax.

Comparative Taxation
(2 Credits) A comparative study of tax systems of the world,
including income and wealth transfer taxes and taxes on con-
sumption. Primary emphasis is on basic structural features and
policies.

Tax Policy
(2 Credits) Examination of the principal criteria used to make
choices on forms of taxation and the impact of tax provisions on
type and location of business and investment activities. Content
may vary.

Tax Treaties
(2 Credits) Bilateral income tax conventions between countries to
alleviate double taxation of income from international investments
and activities and to provide for exchanges of tax information and
consultation between tax authorities.


Transfer Pricing
(2 Credits) Transactions between related entities in connection
with the tax requirement that such transactions be priced as if
between unrelated persons.

International Tax Planning
(2 Credits) Examination of the tax consequences of proposed
cross-border business transactions that are subject to the rules of
multiple taxing jurisdictions.

Taxation of Financial Instruments
(2 Credits) Taxation of income from financial instruments of vari-
ous kinds, including options, futures, forwards, swaps, and other
instruments often referred to as "derivatives."

Taxation of Intangibles
(2 Credits) Capitalization of expenditures in development of intan-
gibles; tax incentives for research and experimentation; amortiza-
tion of intangibles; domestic and cross-border transactions and
transfers; holding companies; treatment of e-commerce.

Current Federal Tax Problems
Significant current developments in tax law, often with emphasis
on policy considerations. Course content and coverage vary.

Independent Study
Students may be allowed to pursue an independent study project
under supervision of a tax faculty member, subject to approval of
the director.

Note: Course offerings vary from year to year. Contact the
Graduate Tax Office for information on current courses.


UF LAW GRADUATE TAX 7


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- Dean Robert H. Jerry, II, Levin Mabie and Levin Professor of Law


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The Graduate Tax Experience

"WONDERFUL PREPARATION"
"It's a very friendly program with a lot of close interaction between the students and the faculty members. It's like
a family. The faculty all have different areas of strength that they bring to the program. My years at UF provided
wonderful preparation for my career."
Lindy Paull (Florida J.D.; LL.M. in Taxation) former Chief of Staff of the Joint Committee on Taxation of the
U.S. Congress, and currently Co-Managing Partner PricewaterhouseCoopers, Washington, D.C. Selected the
Florida Graduate Tax Program because it offered the outstanding academic quality plus the quality of life
and personal attention she desired.

"IMMERSED IN THE CODE"
"The program has a national reputation because of its quality graduates. Any employer who gets a Florida gradu-
ate is guaranteed that their new employee has been immersed in the tax code. It's a great program."
Felicia Branch, Florida LL.M. in Taxation

"PUSHED TO EXCEL"
"I was once asked if there was one professor who pushed me to excel. My instinctive response was no every
professor I worked with at some point encouraged me to test my limits. I also enjoyed the friendships I developed
with fellow students. It adds to the experience and together we pushed each other to excel."
-Joe Zitzka, Florida LL.M. in Taxation

"GREAT ATMOSPHERE"
"It was a great atmosphere; the students were there to learn, and the size of the program allowed me to get to
know everyone well. Faculty take the time to talk with students one-to-one. I was comfortable going to my profes-
sors with any questions or problems."
Kelli Felentzer, Florida LL.M. in Taxation


UF LAW GRADUATE TAX 9
























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Faculty

The Graduate Tax faculty share a strong dedication

to teaching and scholarly research.


Yariv Brauner
Associate Professor of Law
Education: LL.B., 1996, Hebrew University School of Law; LL.M. in International
Taxation, 1998, J.S.D., 2003, New York University School of Law. Teaching and
Scholarship: Taxation.
Joined the Florida faculty in 2006, after teaching at NYU, Northwestern and
ASU. Has been a visiting professor or a guest lecturer in various universities in
the U.S., Australia, Brazil, Israel, Austria, France, Argentina, China, Belgium and
Switzerland. He is an author of several articles published in professional jour-
nals and law reviews and a co-author of U.S. International Taxation Cases and
Materials, 2nd. Ed.

Dennis A. Calfee
Alumni Research Scholar and Professor of Law
Education: B.B.A., 1968, J.D., 1972, Gonzaga University; LL.M., 1975, University
of Florida. Teaching and Scholarship: Taxation of Gratuitous Transfers, Income
Taxation of Estates and Trusts.
Joined Florida law faculty in 1975, and twice has been named Teacher of the
Year. Professor Calfee has taught as a visiting professor at Leiden University,
the Netherlands; Peking University, Beijing, China; Academy of International
Tax, Taipei, Taiwan; and University of Montpellier, Montpellier, France. He is a
co-author of the eighth edition of FederalEstate and Gift Taxation and its supple-
mental study manual.

Patricia E. Dilley
Professor of Law
Education: B.A., 1973, Swarthmore College; M.A., 1976, University of Pennsylvania;
J.D., 1986, Georgetown University; LL.M., 1993, Boston University. Teaching and
Scholarship: Social Security, Retirement Policy, Deferred Compensation, Individual
Income Taxation, Corporate Taxation, International Taxation, Advanced Employee
Benefit Law.
Has taught at Florida since 1997, and formerly at Seattle University School
of Law from 1993-98. Professor Dilley was a member of the professional
staff of the U.S. House Ways & Means Committee from 1981-87, serving as
Staff Director and Chief Counsel of the Social Security Subcommittee from
1985-87. She then practiced law with Arnold & Porter in Washington, D.C., and
with Downs, Rachlin & Martin in Burlington, Vermont. She is a member of the
American Bar Association Employee Benefits Committee, and the National
Academy of Social Insurance. Professor Dilley is past Chair of the Association
of American Law Schools Section on Employee Benefits. She has published
articles in journals and book compilations, and has been a speaker at prestigious
tax institutes.


UF LAW GRADUATE TAX 11
















Michael K. Friel
Associate Dean, Graduate Tax Program Director and Professor of Law
Education: B.A., 1966, J.D., 1969, Harvard University; LL.M., 1982, New York
University. Teaching and Scholarship: Income Taxation.
Joined the Florida law faculty in 1987, after serving as visiting professor in Fall
1986. He was Director of the Graduate Tax Program from 1988-95, and returned
to the position in 1996. Dean Friel practiced law in Oregon for several years,
and taught at New York University and Willamette Law School. He is co-author
of the textbooks Taxation of Individual Income and Understanding Federal
Income Taxation and of the Modern Estate Planning treatise. He has published
numerous articles on various tax topics, lectured at law schools in the U.S. and
abroad, and been a speaker at federal tax institutes.

David M. Hudson
Professor of Law, LL.M. in Comparative Law Program Director
Education: B.S., 1968, Wake Forest University; J.D., 1974, Florida State University;
LL.M., 1975, University of Florida; LL.M., 1980, University of London. Teaching
and Scholarship: Income Taxation, State and Local Taxation, Immigration Law.
Joined the law school faculty in 1980. Professor Hudson assisted in prepara-
tion of the Estate and Gift Tax Digest, and has published articles on taxa-
tion in various law journals. He is an editorial consultant for Commerce
Clearing House's Federal Tax Service, co-author of Black Letter on Federal
Income Taxation, Editor of Florida Tax Review, and Director of the LL.M. in
Comparative Law Program.

Lawrence Lokken
Hugh F. Culverhouse Eminent Scholar in Taxation and Professor of Law
Education: B.A., 1960, Augsburg College; J.D., 1967, University of Minnesota.
Teaching and Scholarship: Taxation.
Has held the Hugh F. Culverhouse Eminent Scholar Chair in Taxation since January
1994, and is former editor of Florida Tax Review. He taught at New York University
from 1980-1993, where he was Editor-in-Chief of the Tax Law Review from
1983-1987. Professor Lokken has been a visiting professor at Duke University,
Northwestern University, Southern Methodist University, the University of
Minnesota, and Leiden University, the Netherlands. He is co-author of Federal
Taxation of Income, Estates & Gifts, and Fundamentals of International Taxation.

Charlene Luke
Assistant Professor of Law
Education: B.A., Brigham Young University; J.D., Brigham Young University (first in
class). Teaching and Scholarship: Income, Corporate and Partnership Taxation.
Charlene Luke joined the Levin College of Law faculty as an assistant professor
in 2008. She was a visiting faculty member at the University of Utah for Spring
2008. She was previously an assistant professor at Florida State University
2003-08. Her private practice experience includes serving as a judicial clerk
for Judge J. Clifford Wallace, U.S. Court of Appeals, Ninth Circuit, San Diego
2000-01; and working for Dechert, LLP, Philadelphia, PA 2001-03.


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Paul R. McDaniel
James J. Freeland Eminent Scholar in Taxation and Professor of Law
Education: B.A., 1958, University of Oklahoma; LL.B., 1961, Harvard Law School
(cum laude); Honorary Doctor of Laws, University of Uppsala, Sweden. Teaching and
Scholarship: Basic Income Taxation, Corporate Taxation, International Taxation.
Professor McDaniel joined the Florida faculty in 2004 as the James J. Freeland
Eminent Scholar in Taxation. He was Professor of Law from 1970-1987 and
2002-2004, and Adjunct Professor of Law from 1992-1993, at Boston College
Law School; and Professor of Law, Director of the Graduate Tax Program, and
Director of the International Tax Program from 1993-2002 at New York University
School of Law, where he also was a Visiting Professor of Law from 1986-87.
He served on the staff of U.S. Senator Albert Gore as Special Assistant on Tax
Matters, and as Attorney Advisor, Office of Tax Legislative Counsel, U.S. Treasury
Department. He is a member of the American Bar Association (Taxation Section),
National Tax Association Tax Institute of America, and International Fiscal
Association. He co-authored Tax Expenditures, International Aspects of Tax
Expenditures: A Comparative Study, Federal Income Taxation, Federal Income
Taxation of Business Organizations, Federal Income Taxation of Corporations,
Federal Income Taxation of Partnerships and S Corporations, and Federal Wealth
Transfer Taxation.

Martin J. McMahon, Jr.
Clarence J. TeSelle Professor of Law
Education: B.A., 1971, Rutgers College; J.D., 1974, Boston College; LL.M.,
1979, Boston University. Teaching and Scholarship: Individual Income Taxation,
Corporate Taxation, Partnership Taxation, Tax Policy.
Professor McMahon joined the Florida faculty in 1997, after teaching at the
University of Kentucky from 1979-1997. He has served as Professor-in-Residence
in the Office of Chief Counsel of the Internal Revenue Service, and has been a
visiting professor at the University of Virginia. He is a member of the American
Law Institute, American College of Tax Counsel, and American Bar Association
Tax Section. He is past Chair of the ABA Teaching Taxation Committee and the
Association of American Law Schools Tax Section. He is co-author of four case-
books, including Federal Income Taxation Cases and Materials, Federal Income
Taxation of Partnerships and S Corporations, and Federal Income Taxation of
Corporations, and a treatise titled Federallncome Taxation of Individuals. He has
published more than 50 major articles on taxation, and is a regular speaker at tax
institutes across the country.


UF LAW GRADUATE TAX 13
















C. Douglas Miller
Professor of Law
Education: B.S., 1962, J.D., 1965, University of Kansas; LL.M., 1996,
New York University. Teaching and Scholarship: Estate Planning and
Federal Taxation.
Joined the Florida faculty in 1973, after practicing in the Midwest since
1966. He was voted Teacher of the Year 1995-96 and 1997-98, and has been
a visiting professor at Arizona State University and Leiden University, the
Netherlands. Professor Miller's publications include materials for use in the
Graduate Tax Program, and articles in law reviews. He has served as a mem-
ber of the Executive Committee of The Florida Bar Sections of Taxation and
General Practice, as consultant to the Florida Bar Wills, Trusts and Probate
Certification Committee, and as a principal speaker in federal tax and estate
planning institutes and seminars.



Steven J. Willis
Professor of Law
Education: B.S., 1974, J.D., 1977, Louisiana State University; LL.M., 1980, New York
University. Teaching and Scholarship: Partnership Taxation, Tax Exempt Organizations,
Income Taxation I and II.
Professor Willis joined the Florida faculty in 1981. He is a Certified Public
Accountant, previously practiced law in New Orleans, clerked at the trial
court level for Judge W. Eugene Davis of the U.S. District Court (Western
District), and taught at New York University. He has published a number of
articles on taxation.


VISITING FACULTY 2008-2009


Linnie Benezech
Visiting Assistant Professor of Law
Education: B.S., 2001, Louisiana State University; J.D./B.C.L., 2004, Paul M. Hebert
Law Center, Louisiana State University; LL.M., 2005, University of Florida Levin
College of Law. Order of the Coif. Graduate Tax Scholar. VITA Supervisor/Coordinator
2003-2004.
Each year the tax law faculty recommends a candidate for Visiting Assistant
Professor of Law from a pool of outstanding graduates and current students.
The selection is based upon scholarship, academic record, potential for
teaching, the nature of the candidate's experience, and an expressed desire
to contribute to the field of legal education. Linnie Benezech was selected
for this position for 2008-2009.


14 WWW.LAW.UFL.EDU/TAX







I UI I! y


UF LAW GRADUATE TAX 15


1101


















Graduate Tax Admissions


APPLYING TO THE LL.M. IN TAXATION AND
LL.M. IN INTERNATIONAL TAXATION PROGRAMS
Enrollment is limited to applicants who have attained a Juris
Doctor or equivalent degree from a law school accredited
by the Association of American Law Schools and applicants
who hold law degrees from recognized foreign universities.
However, graduates of law schools accredited or provi-
sionally accredited by the American Bar Association may
be considered for admission on the basis of outstanding
credentials.

Admission is determined by the applicant's potential for dis-
tinguished performance in and contribution to the program.
The candidate's academic record, especially in law school,
is of particular importance. Additional factors may include
the stature of the institutions awarding the baccalaureate
and law degrees, the applicant's professional experience
and geographical factors.

Generally, successful candidates have graduated within
the top quarter of their law school class, and have attained
an honors average in their baccalaureate work. With these
academic records, especially in law school, as the basic
considerations, the potential of each applicant is measured
against that of other candidates. The objective of the admis-
sions policy is to fill each class with the best students from
the applicant pool, consistent with maintenance of the pro-
gram's high admission standards.

Full-time students in the LL.M. in Taxation program will be
admitted in the fall term; part-time students may begin the
program in the fall or spring, subject to approval of their
course load.

The LL.M. in International Taxation is limited to full-time stu-
dents and to admission in the fall term. Students may not
be admitted to both LL.M. degree programs and may not
obtain both LL.M. degrees.

Applicants to the LL.M. in Taxation and LL.M. in
International Taxation programs must apply between
October 1 and June 1 for admission the following August.
For application forms and information, contact the Graduate
Tax Office, University of Florida, College of Law, P.O. Box
117627, Gainesville, FL 32611-7627; Phone 352-273-0680;
Fax 352-392-7647, or visit the web at www.law.ufl.edu/tax/.

Applicants should submit two letters of recommendation, a
personal statement or resume, and their LSDAS Law School
Report with their applications and transcripts.


Applicants holding law degrees from foreign universities
should submit two letters of recommendation, a personal
statement or resume, and a TOEFL examination score
report or other approved English proficiency score report,
with their applications and transcripts.


APPLYING TO THE S.J.D. IN TAXATION PROGRAM
The S.J.D. in Taxation degree is open to a limited number
of outstanding graduates of U.S. law schools and those
who hold law degrees from foreign universities. It is antici-
pated that no more than one or two applicants will be
accepted into the S.J.D. program during the year. Principal
criteria for admission include, in addition to academic
record and experience, an applicant's potential for success
in a teaching career and the program's ability to meet the
applicant's research needs, including a member of the tax
faculty to serve as the applicant's advisor. Admission will
be limited to full-time, fall semester enrollment. Students
may not obtain the S.J.D. in Taxation degree and the LL.M.
in Taxation or LL.M. in International Taxation degree.

Applications should be submitted between October 1
and February 1 for admission the following August. For
application forms and information, contact the Graduate
Tax Office, University of Florida College of Law, P.O. Box
117627, Gainesville, FL 32611; Phone 352-273-0680; Fax
352-392-7647, or visit the web at http://www.law.ufl.edu/
programs/djst/.


PART-TIME STUDENTS
The Graduate Tax Program is primarily for full-time degree
candidates. However, students seeking the LL.M. in Taxation


16 WWW.LAW.UFL.EDU/TAX












































degree may enroll on a part-time basis and seek to obtain
the LL.M. degree over the maximum enrollment period of
five years. Those wishing to enroll on a part-time basis must
apply in the same manner as full-time students, and will be
held to the same admissions standards and degree require-
ments. Under current Graduate School policy, part-time
degree candidates must register for a minimum of three
credits during the fall and spring semesters, and two credits
during the summer.

TUITION
Tuition for the Graduate Tax Program for the 2008-2009
academic year is $411.30 per credit for Florida residents
and $1,056.79 per credit for non-residents. Tuition for future
years is determined in late spring or summer. Contact the
Graduate Tax Program Office for more information.


HOUSING
For information regarding on- and off-campus housing,
contact the University of Florida Division of Housing,
P.O. Box 112100, Gainesville, FL 32611-2100; Phone:
352-392-2161; Fax: 352-392-6819; E-mail: houinfo@hous-
ing.ufl.edu. New and current UF law students also may
access the UF College of Law Roommate Referral System
online for assistance in finding roommates. Go to www.law.
ufl.edu, click on "Admissions," then "Housing."

COMPUTER REQUIREMENT
The Fredric G. Levin College of Law relies extensively on
computing technologies and network communications in all
aspects of student life. We believe it is imperative to prepare
our students to be technologically sophisticated in the use of
computers and computerized legal research. Because of this


major emphasis on access to network information, the Levin
College of Law requires that all entering students own a
portable (notebook or laptop) computer. For more informa-
tion on technology services and requirements, go online to
www.law.ufl.edu/services/ or contact Levin College of Law
Computing Services at computingservices@law.ufl.edu.


UF LAW GRADUATE TAX 17

















Financial Aid


FLORIDA GRADUATE TAX SCHOLARS
Students accepted to the LL.M. in Taxation or LL.M.
in International Taxation are considered for available
financial assistance, which is typically awarded in the
form of a graduate assistantship or other research assis-
tantship appointment. The Graduate Tax Program des-
ignates the recipients of such assistantships as Florida
Graduate Tax Scholars.


Each recipient of an assistantship works with a mem-
ber of the tax faculty as a research assistant or with the
Florida Tax Review as a student editor. Each recipient
is awarded a stipend plus a scholarship or a stipend plus
a partial tuition waiver. In many cases, the award will
cover all or most of the cost of tuition for the semester or
semesters awarded. Assistantship appointments are made
based on the student's record and the research needs of
the tax faculty, and no separate application is required.
Appointments will generally be made on or after April 1
from among those accepted to the LL.M. in Taxation or
LL.M. in International Taxation programs as of the time
of the appointment.

SCHOLARSHIPS & AWARDS
The following scholarships and awards, as referenced
above, are typically made in conjunction with a stu-
dent's appointment to serve as a research assistant for a
member of the tax faculty or as a student editor for the
Florida Tax Review:
* Dean Mead Egerton Bloodworth Capouano &
Bozarth Scholarship: This law firm established this


scholarship endowment through a $100,000 gift and
$50,000 in state matching funds to provide annual
awards for one or more students.
* Dorini Family Graduate Tax Scholarship: Fort Lauder-
dale businessman Donald K. Dorini established this fund
through a $100,000 gift and $50,000 in state matching funds
to provide annual awards for one or more students.
* The Florida Bar Tax Section Award: The Florida Bar
Tax Section annually provides one or more awards based on
academic achievement.
* James J. Freeland Scholarship: Established in 1995 in
honor of the late Distinguished Service Professor Emeri-
tus James J. Freeland, co-founder and director of the UF
Graduate Tax Program, 1977-1982. Each year, one or more
outstanding students may receive Freeland scholarships.
* Janice Dawson Quinn Graduate Assistantship: Or-
lando attorney and alumnus A. Brian Phillips established
this award to provide a graduate assistantship annually
for a tax student.
* Mark A. Rentenbach Memorial Fund: Established in
memory of 1983 graduate Mark A. Rentenbach by Mark's
mother (Elizabeth H. Rentenbach), classmates and the tax
faculty to provide annual awards to one or more students.
* Richard B. Stephens Fund: Established in honor of the
late Professor Richard B. Stephens, co-founder and first
director of the Graduate Tax Program. The fund provides
annual awards to one or more students. In addition, the
fund provides an award at the end of the academic year
to the overall outstanding student as determined by the
Graduate Tax faculty.
* John W. Thatcher Graduate Tax Scholarship: John
W. Thatcher, a Miami businessman, established this
$100,000 scholarship fund which, combined with $50,000
in state matching funds, supports one or more awards
each academic year.


OTHER FINANCIAL AID
* Ralph R. Bailey Scholarship: Established by the estate of
Ralph R. Bailey for incoming UF students who were bona
fide residents of Broward County, Florida, for the year prior
to the date of application.
* International Students: For information about "Linkage
Institute" programs with several countries and regions and/
or scholarships for students from Latin America or the
Caribbean, see page 4.
* Loans: A variety of loans, including Guaranteed Student
Loans, are available. Early application is encouraged to
allow adequate processing time before start of a term. For
information and applications, write: University of Florida,
Student Financial Affairs, Room S103, Criser Hall, P.O.
Box 114025, Gainesville, FL 32611-4025. Short-term loans
in limited amounts may be available through the Graduate
Tax Program.


18 WWW.LAW.UFL.EDU/TAX

































bAG aduateTaAjProgranj hosts a variety of social events for
SS'uch as thnanpual picnic at nearby Lake Wauburg.


Law at Florida


WORLD CLASS OPPORTUNITIES
The Graduate Tax Program is a distinctive
part of a preeminent research university and
of a law school that is one of the nation's
most comprehensive. Founded in 1909, the
Levin College of Law is accredited by the
American Bar Association and is a member
of the Association of American Law Schools.
Student and faculty research is supported
by one of the nation's leading law libraries,
the newly expanded and renovated Lawton
Chiles Legal Information Center.

The University of Florida was founded in
1853, and is one of only 30 public uni-
versities in the prestigious Association of
American Universities, which recognizes
outstanding North American graduate
research universities. Professional degrees
are offered in law, dentistry, medicine,
pharmacy and veterinary medicine. The
university offers a wide variety of social and
extracurricular activities, including sport-
ing events, art and natural history exhibits,
performance arts, several gyms and pools.
A Center for Performing Arts features
Broadway touring productions, operas,
ballet, symphony orchestras and world-
famous performers, while local venues offer
first-class theater and popular productions.


With a population of approximately 110,000,
Gainesville is located between the Atlantic
Ocean and Gulf of Mexico, approximately
two hours by car from either coast as well
as from major cities such as Orlando, Tampa
and Jacksonville and is on the 1-75 cor-
ridor halfway between Atlanta and Miami. Its
moderate temperature averages 70 degrees.
Money magazine and other publications
consistently rate it as one of America's
most livable cities, and Outdoor Explorer
magazine identified Gainesville as one of the
nation's top 10 cities for outdoor recreation.
The area is dotted with lakes, rivers and
springs, and offers numerous opportunities
for outdoor sports, including boating, diving,
bicycling and hiking.

Local historical sites, festivals, special
events, shopping and award-winning res-
taurants enhance Gainesville's rich cultural
and entertainment offerings. UF's Gator
football, basketball and other top-ranked
men's and women's athletic programs
offer an exciting variety of sports activities.


UF LAW GRADUATE TAX 19


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Career Services


Professional career counselors in the Center for Career
Services offer a wide variety of services and programs to
help students enrolled in the Graduate Tax Program plan
a self-directed career search and develop marketing skills
that will serve them throughout their career in an increas-
ingly competitive employment arena. These advisors
help students present legal credentials, capitalize on their
diverse strengths and experiences, explore career paths,
and link tax students with alumni, practitioners and the
community. A Graduate Tax Program orientation occurs


Specialized career services are available to Graduate Tax
Program students and alumni.



in August each year to prepare tax students for upcoming
application deadlines, recruiting events and job strategy
information. While many tax students are successful
in the on-campus interviewing program, the unique
experiences and career paths of tax students encourage
the development of well-rounded search strategies to
serve them beyond on-campus interviewing. Through the


Center for Career Services at the Levin College of Law,
Graduate Tax students have access to such services as:
* Ongoing career counseling and planning
* Programs / panels featuring attorneys, judges and
legal recruitment professionals
* Resume and cover letter review service
* On-campus interviews and resume collects for
interested employers
* Video conference interviews
* UF College of Law online job bank
* Networking events on- and off-campus
* Employer directories and online databases, such as
Martindale-Hubbell and National Association for
Law Placement
* Bibliography of career resources

RECRUITING
Employers from across the nation interview LL.M. Tax
students on campus and during the Annual Tax Attorney
Recruiting Event held in Washington, D.C. Employers
post position openings and request resume collections
from Florida Graduate Tax Program students. Tax Pro-
gram graduates are employed with law firms, accounting
firms and government agencies throughout the nation
and abroad. Many students have found that alumni are
uncommon in their dedication to supporting students
whenever and wherever they can.

PLACEMENT SUCCESS
Our graduates are employed in every state and in a num-
ber of foreign countries. Approximately 80 percent of the
graduates have accepted employment in law firms. About
10 percent were employed by international accounting
firms. The remaining estimated 10 percent were em-
ployed in government or corporate positions, in judicial
clerkships or in academia.


20 WWW.LAW.UFL.EDU/TAX






































2009-10


2010-11


FALL SEMESTER
Classes start August 25 August 24 August 23
Classes end December 5 December 4 December 3
Exam/reading period starts December 8 December 5 December 6
Exam/reading period ends December 19 December 18 December 17

SPRING SEMESTER
Classes start January 9 January 4 January 3
Classes end April 24 April 16 April 15
Exam/reading period starts April 27 April 19 April 18
Exam/reading period ends May 8 April 30 April 29
Graduation Ceremony May 15 May 7 May 6


SUMMER TERM
Classes start
Classes end
Exam/reading period starts
Exam/reading period ends


May 21
July 10
July 13
July 17


May 10
June 28
June 28
July 6


May 16
July 6
July 11
July 15


CONTACT INFORMATION

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Gaine_-i.,lle FL 32t:.1 1-7ti.27
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UF LAW GRADUATE TAX 21


Academic Calendar
2008-09
































UF Law:


* Includes the GRADUATE TAX PROGRAM, which offers the LL.M. in
Taxation, LL.M. in International Taxation and S.J.D. in Taxation and is widely
and consistently regarded as one of the nation's top programs.

* A HIGH QUALITY, COMPREHENSIVE LAW SCHOOL, with approximate-
ly 1,300 students, 100 full-time faculty, a wide range of courses, certificate
programs in various areas of law, an extensive array of joint degree programs,
and specialized centers, institutes and clinics.
* A LONG-STANDING TRADITION OF PREPARING ITS GRADUATES
FOR SIGNIFICANT LEADERSHIP ROLES. Its alumni include presidents of
the American Bar Association, judges in U.S. federal and state courts, college
presidents and law school deans and professors.





UF UNIVERSITY of
UFLORIDA
Levin College of Law
P.O. Box 117627
Gainesville, FL 32611-7627


Graduate Tax Online
Access the latest on University of
Florida Levin College of Law Graduate
Tax faculty, programs and events, a
variety of legal links and more at
www.law.ufl.edu/tax




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