Law School Audio Flashcards

Epizody

• 16.5. SALT - Individual Taxation, Credits, and Remote Work 30.04.2026 13min

  For our fifth and final episode in the SALT series, we are going to discuss general principles of individual multi-state taxation, the use of the OSTC (other-state tax credit), and modern issues arising from the prevalence of remote work.I hope you enjoyed this series. If there are any other subjects you would like me to cover, please let me know in the comments or by DM.
• 16.4. SALT - Consumption-Based Taxes 29.04.2026 11min

  In Episode 4 of 5 in our SALT series, we will examine consumption taxes, such as sales and use taxes and related amalgamations thereof in this modern digital economy.
• 16.3.SALT - Dividing the Pie: Apportionment and Unitary Businesses 28.04.2026 12min

  This is Episode 3 of 5 of our accelerated series on SALT (State and Local Taxation). Today we are tackling one of the most mechanically complex but conceptually fascinating areas of State and Local Tax: Apportionment and the Unitary Business Principle. We must answer the question: once a state has the constitutional authority to tax a multistate corporation, exactly how much of that corporation's income can it actually tax?
• 16.2. SALT - P.L. 86-272 - Federal Intervention 27.04.2026 11min

  For Episode 2 of 5 of our accelerated series on SALT, we will examine P.L. 86-272, codified at 15 U.S.C. §381, a rare instance of Congressional intervention of states' sovereignty to tax activity within its borders.
• 16.1. SALT (State and Local Tax) - Constitutional Thresholds 21.04.2026 12min

  For our first episode in the five-part series on State and Local Tax, or SALT, we will examine the Constitutional limitations on states' imposition of tax on both residents and nonresidents and the history of jurisprudence starting in the mid-20th century until today.
• 15.8. Corporate Tax - Tax-Free Reorganizations 20.04.2026 8min

  For our eighth and final episode of our series on Corporate Tax, we will examine the tax-free reorganization provisions under §368(a)(1) and the related basis provisions. Please let me know if there are any other subjects you'd like me to cover.-Guy
• 15.7. Corporate Tax - Deemed Asset Deals 16.04.2026 9min

  In the seventh episode of our Corporate Tax series, we will review the principles contained under §§ 1060, 338, and 336(e), each relating to the tax treatment of a taxable asset sale.
• 15.6. Corporate Tax - Entity Level Liquidations (§§ 336, 332/337 14.04.2026 12min

  Episode 6 in our Corporate Tax series covers the entity level liquidation implications codified under §336 and the related provisions under §§ 332 and 337 pertaining to parent-sub scenarios. Finally, we will briefly touch on the residual allocation method prescribed under §1060 for business acquisitions structured as asset deals for tax purposes.
• 15.5. Corporate Tax - Stock Dividends, Corporate Liquidations 13.04.2026 13min

  Episode 5 is a long one, covering stock dividends under §305 and corporate liquidations under §331, along with the basis rules for each provision under §307(a) and §334(a) respectively, plus some ancillary or related provisions.
• 15.4. Corporate Tax - Part II of §302 Redemptions 10.04.2026 9min

  In Episode 4 of our Corporate Tax series, we will review the "not essentially equivalent" to a dividend standard, the corporate contraction doctrine codified under §302(e), and §312(n)(7) adjustments to E&P resulting from §302 treatment.
• 15.3. Corporate Tax - §302 Redemptions - I of II 09.04.2026 13min

  In Episode 3, we will explain redemptions (as defined under §317(b)) under IRC §302 and also introduce attribution under §318.
• 15.2. Corporate Tax - Distributions - §301, §312, and §316 08.04.2026 10min

  For Episode 2 of our Corporate Tax series, we will review the treatment of corporate distributions under §§ 301, 312, and 316.
• 15.1. Corporate Tax - Double Tax, Formation, and Basis (§§ 351, 357, 358, 362) 03.04.2026 13min

  In this inaugural episode of the Corporate Tax series, we will discuss the concept of the corporate double tax in US taxation, formation of a C-corporation, and calculation of the shareholder's stock basis and the corporation's inside property basis.
• 14.10. International Tax - Master Review 27.03.2026 16min

  In our final episode, we will do a high-level review of our international tax survey course, along with recommended approaches to different types of fact patterns.
• 14.9. Treaties & The 2026 Horizon 26.03.2026 7min

  In this episode, we will review the topic of tax treaties in international taxation.
• 14.8. The Foreign Tax Credit (FTC) – Baskets, Haircuts, and the OBBBA 17.03.2026 7min

  In this episode, we will examine foreign tax credits a post-OBBBA world.
• 14.7. The Export Benefit – FDDEI (§ 250) 13.03.2026 9min

  In this episode, we will examine §250 Foreign-Derived Deduction Eligible Income.
• 14.6. Outbound – The New NCTI (§ 951A & The OBBBA Era) 12.03.2026 11min

  In this episode, we will review GILTI and NCTI in 2026.
• 14.5. The Subpart F Regime (§§ 951–954) 11.03.2026 7min

  For Episode 5, we will be examining the Subpart F regime under §§ 951-954.
• 14.4. International Tax - Expatriation and the Branch (§§ 877, 877A, and 884) 11.03.2026 9min

  For this episode, we will look at expatriation under §§877 and 877A, and the Branch Profits Tax under § 884.