Taxation

Taxation

Master of Taxation
For the award of the Master of Taxation, students must complete 48 credit points from the following list.
Graduate Diploma of Taxation
For the award of the Graduate Diploma in Taxation, students must complete 24 credit points from the following list.
LAWS6209 Australian International Taxation

Credit points: 6 Teacher/Coordinator: Prof Michael Dirkis Session: Intensive August Classes: Jul 22-24 & 27, 28 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. The completion of other foundation units such as LAWS6840 Taxation of Business and Investment Income A and LAWS6841 Taxation of Business and Investment Income B will provide students; without such knowledge or work Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
Australian International Taxation is a detailed study of the fundamental principles of Australia's international taxation regime as it applies to cross-border business and investment transactions. The unit focuses on corporate residence, source, non-resident withholding tax, relief from international double taxation, CFCs, transferor trusts and transfer pricing. This advanced unit will examine both the issues of international tax rule design and policy, and the relevant provisions in the legislation, cases and rulings. The unit focuses on the international tax rules in Australia's domestic law. Although the role of double tax treaties is introduced, double tax treaties are covered in the companion unit Tax Treaties. Students should gain an understanding of the policies underlying Australia's rules for taxing international transactions, as well as a detailed knowledge of the foundation principles of law applicable to the taxation of inbound and outbound transactions.
LAWS6091 Chinese International Taxation

Credit points: 6 Teacher/Coordinator: Prof Jinyan Li Session: Intensive May Classes: May 6-8 & 11, 12 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have successfully completed an undergraduate/postgraduate unit of study in tax law. Assessment: class participation (20%) and take-home exam (80%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
The object of this unit is to provide an overview of the income tax system of China and a detailed analysis of the most important legislative and treaty rules of China in the area of international income tax, especially in dealings with Australia. Upon successful completion of the unit, students will have an advanced understanding of the policies underlying the Chinese rules for taxing international transactions as well as a detailed knowledge of the principles of income tax law applicable to inbound and outbound transactions. This unit includes a study of: overview of the Chinese income tax system; taxation of inbound investment into China; taxation of outbound investment from China; transfer pricing issues, and China's tax treaties.
LAWS6153 Comparative Corporate Taxation

Credit points: 6 Teacher/Coordinator: Prof Peter Harris Session: Intensive April Classes: Mar 25-27 & 30, 31 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have successfully completed an undergraduate/postgraduate unit of study in tax law. Assessment: in-class test (20%) and 2hr exam (80%) or with permission 6000wd essay (80%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
Globalisation is driving corporate tax systems closer together and often into conflict. For many tax practitioners, it is now not enough to know their own corporate tax system - they must grapple with and question the operation of other corporate tax systems. This unit seeks to develop an ability to understand and analyze any corporate tax system and assess its impact on corporate decision making. With a dedicated textbook (written by the presenter), it does this by comparing a number of influential and archetypal corporate tax systems (both common law and civil law) and assessing their behaviour in the context of a number of practical problems. For tax professionals, the unit develops an ability to ask direct and informed questions about a foreign corporate tax system and discuss that system at a high level with foreign tax professionals. Topics include: corporate entities and hybrids, groups, interface with accounting, service companies, debt vs. equity, dividend relief, cross-border issues, incorporation, takeovers, trading in loss companies, share buy-backs, liquidation, bonus issues, convertible notes, mergers and demergers. This unit considers and contrasts (to the extent relevant) the US tax reforms implemented at the start of 2018.
LAWS6128 Comparative International Taxation

Credit points: 6 Teacher/Coordinator: Prof Brian Arnold Session: Intensive November Classes: Oct 27, 28 & Nov 2, 3 (9-5) Assumed knowledge: It is assumed that students undertaking this unit have successfully completed an undergraduate/postgraduate unit of study in tax law. Assessment: in-class test (20%) and 2hr exam (80%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
Comparative International Taxation is a detailed study of the basic principles of international taxation (residence, source, relief from international double taxation, anti-deferral rules, withholding tax, transfer pricing, thin capitalisation, and tax treaties). The unit is taught from a global perspective with the emphasis being on comparative analysis (focusing particularly on Anglo, US and continental European approaches, and also developed and developing country approaches). The unit examines the core issues in developing international tax rules and identifies different approaches countries have taken in dealing with these issues. As part of this study, recent trends in international tax rule development will be identified (particularly in the context of globalisation) and critiqued. Students should gain an understanding of the different approaches that countries have taken in the development of their international tax rules.
LAWS6030 Corporate Taxation

Credit points: 6 Teacher/Coordinator: Prof Richard Vann Session: Intensive April,Semester 1a Classes: Law School Group (Session S1CIAP): Apr 1-3 & 6, 7 (9-3.30). Please refer to Law School timetable https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-homepage. Deloitte Regional Group (Session S1CRA): First class starts on Feb 4 and concludes on Mar 19. Please refer to the Deloitte timetable. Law School students are not permitted to enrol into the Deloitte group. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. The completion of other foundation units such as LAWS6840 Taxation of Business and Investment Income A and LAWS6841 Taxation of Business and Investment Income B will provide students; without such knowledge or work experience; with additional knowledge and skills that will assist in successfully completing this unit. Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Department permission required for enrolmentin the following sessions:Semester 1a
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This advanced unit covers the tax policy and detailed rules for companies and shareholders designed to ensure that corporate profits are not subject to double taxation in Australia. Topics to be covered include: the policy and problems of taxing companies and shareholders; taxation of company distributions and dealings with interests in companies; imputation; debt equity classification; special anti-avoidance rules dealing with taxation of companies and shareholders; bonus issues, rights issues, share buybacks and liquidations.
LAWS6984 Economics of Tax Policy

Credit points: 6 Teacher/Coordinator: Prof Patricia Apps Session: Intensive October Classes: Sep 28, 29 & Oct 6, 7 (10-5) Prohibitions: LAWS6257 or LAWS3447 or LAWS5147 Assessment: class participation and presentation (10%) and 5000-6000wd essay (90%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
The objective of the unit is to provide an understanding of the modern economics approach to the analysis of tax policy. The unit defines the role of taxation within the framework of welfare economics and examines the social and economic effects of reforms drawing on available empirical evidence. Particular attention is given to the evaluation of current policies and proposed reforms in terms of distributional outcomes and efficiency costs due to disincentive effects on labour supply, saving and investment. Topics covered include: taxation of labour income, consumption and capital income, family income taxation, alternative approaches to the taxation of emission, and the taxation of resource rents.
LAWS6214 Goods and Services Tax Principles A

Credit points: 6 Teacher/Coordinator: Prof Rebecca Millar Session: Intensive April Classes: Mar 11-13 & 16, 17 (9-4) Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. Assessment: class work/test (35%) and 2hr exam (65%). A research essay may be undertaken in lieu of the exam with the permission of the Unit Coordinator. Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This unit introduces the key concepts that underpin the Australian GST, the policies underlying the tax, and the way those policies are (or are not) reflected in the design of the GST law. The aim is to give participants a working knowledge of the operation of the GST law and an awareness of the practical problems encountered in practice, informed by an understanding of the way in which the law is intended to operate.
The unit will commence with an examination of the basic design features of value added taxes in general and of Australia's GST in particular. It will then examine the core elements of the GST law, including: the taxpayer (entities, enterprise, and the obligation to register for GST), the liability for tax on supplies made for consideration; the value of taxable supplies and the amount of GST payable on supplies; the entitlement to input tax credits and the range of subsequent adjustments that may be required; attributing GST and input tax credits to tax periods; adjustments for adjustment events; basic principles of GST-free and input taxed supplies (including an introduction to real property transactions and intermediation services, primarily focussing on financial supplies); basic cross-border issues, including the treatment of imports and exports.
LAWS6326 Interpretation of Statutes and Other Texts

Credit points: 6 Teacher/Coordinator: Ms Chloe Burnett Session: Intensive November Classes: Oct 7-9 & 12, 13 (9-4) Assessment: assignment (30%) and take-home exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
Students will develop their understanding of the principles of statutory interpretation, and hone their ability to apply those principles in practice. The interpretation of contracts, constitutions and treaties will also be explored, observing where the core principles of statutory interpretation (text, context and purpose/intent) also apply to those texts, as well as learning rules particular to contracts, constitutions and treaties. Interpretation is a day-to-day task of the lawyer but many practising lawyers (and other professionals who work with the law) do not have a background in the discipline. This unit will teach the principles of interpretation, with a particular focus on practical application through the use of real-world examples, in-class exercises, and 'how to' guides. The unit will cover topics in- (i) Statutory interpretation (7 lectures): Modern approach, text, context and purpose; Canons and presumptions; Overlap and boundaries with common law; Acts interpretation legislation; Regulations and other subordinate legislation; The role of extrinsic materials; Practical steps to take when construing a provision; Exercises in commercial, administrative, environmental, labour and tax statues; and Recent controversies and the approach of the current High Court (ii) Contract interpretation (2 lectures): A private instrument: similarities and differences to statutory interpretation; and Surrounding circumstances and status of Codelfa 'true rule' (iii) Constitutional interpretation (1.5 lectures) - Dynamic document or original intent; and Practical examples from Commonwealth and NSW constitutions and (iv) Treaty interpretation (1.5 lectures) - Vienna Convention on the Law of Treaties; Treaty obligations and domestic legislation; and Exercises in international arbitration, immigration, environmental, insolvency and tax law. Two of the above lectures will be given by guest lecturers from the judiciary and senior bar. The final two lectures will involve revision and overview, additional problems and assessment preparation.
LAWS6825 Introduction to Australian Business Tax

Credit points: 6 Teacher/Coordinator: Intensive March S1CIMR (Group A): Prof Graeme Cooper and Intensive September S2CISE (Group B): Assoc Prof Celeste Black Session: Intensive March,Intensive September Classes: Intensive March S1CIMR (Group A): Mar 4-6 & 9, 10 (9-3.30) and Intensive September S2CISE (Group B): Aug 12-14, 17-18 (10-5) Assessment: class work/test (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This unit introduces the basic elements of Australia's income tax (including fringe benefits tax and capital gains tax) and Goods and Services Tax, with an emphasis on their impact on businesses, whether conducted directly or via a partnership, trust or company.
The unit covers the following topics: the main structural features of the tax system; assessability of business revenue; treatment of business expenses; timing rules for revenue and expense recognition; trading forms (companies, partnerships, trusts), capital raising and costs of servicing invested capital; cross-border issues; and anti-avoidance rules.
Textbooks
Cooper, Dirkis, Stewart & Vann, Income Taxation: Commentary & Materials (Thomson Reuters) [current edition]
LAWS6257 Public Policy

Credit points: 6 Teacher/Coordinator: Prof Patricia Apps Session: Intensive September Classes: Sep 3, 4 & 10, 11 (10-5) Prohibitions: LAWS6139 or LAWS6042 or LAWS6113 or LAWS6984 or LAWS3447 or LAWS5147 Assessment: 1000wd essay (10%), class presentation (10%) and 5000-7000wd essay (80%) Mode of delivery: Block mode
Note: Core unit for MALP students. Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
The aim of the unit is to provide an understanding of the role of government policy within the analytical framework of welfare economics. Questions of central interest include: What are the conditions that justify government intervention? How can policies be designed to support basic principles of social justice? What kinds of reforms promote economic efficiency? Applications will range from taxation and social security to environmental regulation and protection, and will cover the following specific topics: The structure of the Australian tax-benefit system; Uncertainty and social insurance; Unemployment, health and retirement income insurance; Externalities, environmental taxes and tradeable permits; Monopoly and environmental regulation; Utility pricing and access problems; Cost benefit analysis, intergenerational equity and growth. The unit will provide an overview of the main empirical methodologies used in evaluating policy reforms in these areas. Students may select to specialise in one or more of the policy areas.
LAWS6840 Tax of Business and Investment Income A

Credit points: 6 Teacher/Coordinator: Prof Graeme Cooper Session: Intensive March,Semester 1,Semester 1a Classes: Law School Group (S1C): 1x2-hr lecture/week. First class starts on Feb 19, 8-10am. Please refer to the Law School timetable https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-homepage. Deloitte Sydney Group (S1CIMR) and Deloitte Regional Group (S1CRA), please refer to the Deloitte timetable. Law School students are not permitted to enrol into the Deloitte groups. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. Assessment: class work (30%) and 2hr exam (70%) Mode of delivery: Normal (lecture/lab/tutorial) day
Note: Department permission required for enrolmentin the following sessions:Intensive March,Semester 1a
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php
This unit, along with LAWS6841 Taxation of Business and Investment Income B, is designed to provide an advanced study of the tax treatment of various important business transactions. It provides a detailed examination of the income tax and capital gains treatment of selected complex commercial transactions and their impact on the tax base. The goal of the unit is to develop an understanding of the policies, detailed rules and current practical problems involved in this area of taxation, through the analysis of a number of specific problems discussed in each seminar. Because of continual change to the taxation system, recent legislative amendments and judicial decisions will be examined in detail where applicable. The unit will cover the following topics: core income and expense rules and operational concepts underlying the income tax system; treatment of realised business income and the differentiation of capital gains; treatment of business expenses and the differentiation of expenses recoverable under depreciation, CGT or not at all; issues in the treatment of trading stock; issues in the tax treatment of the costs (and revenues) associated with business equipment and intangibles. This unit can be taken alone or in conjunction with LAWS6841 Taxation of Business and Investment Income B.
LAWS6841 Tax of Business and Investment Income B

Credit points: 6 Teacher/Coordinator: Mr Micah Burch, Assoc Prof Celeste Black Session: Intensive September,Semester 2,Semester 2a Classes: Law School Group (S2C): 1x2-hr lecture/week. First class starts on Jul 29, 8-10am. Please refer to Law School timetable https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-homepage. Deloitte Sydney Group (S2CISE) and Deloitte Regional Group (S2CRA), please refer to the Deloitte timetable. Law School students are not permitted to enrol into the Deloitte groups. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. Assessment: class work (30%) and 2hr exam (70%) Mode of delivery: Normal (lecture/lab/tutorial) day
Note: Department permission required for enrolmentin the following sessions:Intensive September,Semester 2a
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php
This unit, along with LAWS6840 Tax of Business and Investment Income A, is designed to provide an advanced study of the income and capital gains tax treatment of various complex commercial transactions. The goal of this unit is to develop an understanding of the policies, detailed rules and current practical problems involved in this area of taxation, through the analysis of a number of specific problems that will be discussed in the seminars. Because of continual change to the taxation system, recent legislative amendments and judicial decisions will be examined in detail where applicable.
This unit will cover the following topics: issues in business financing, including asset leasing; tax issues related to the use and development of land and buildings; the treatment of 'black hole' expenses; tax accounting for income, expenses and profits; and specific and general anti-avoidance rules. This unit can be taken alone or in conjunction with LAWS6840 Tax of Business and Investment Income A.
LAWS6177 Tax Treaties

Credit points: 6 Teacher/Coordinator: Prof Richard Vann Session: Semester 1 Classes: 2x2-hr lecture/week. Classes are held every Mon and Wed 6-8pm. First class commences on Mon 17 Feb and concludes on Wed 1 Apr 2020. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. The completion of LAWS6209 Australian International Taxation will provide students; without such knowledge or work experience; with additional knowledge and skills that will assist in successfully completing this unit. Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Normal (lecture/lab/tutorial) evening
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This unit is designed to study the policy, detailed rules and practical application of Australia's international tax treaties against the background of the OECD Model Tax Convention on Income and on Capital. Upon successful completion of this unit a student should have an advanced understanding of the policies underlying the Australian tax treaty position in relation to the taxation of various kinds of income, as well as a detailed knowledge of the law applicable to interpretation of Australia's treaties. The unit includes a study of: principles of tax treaties; interpretation of tax treaties; and selected articles of the OECD Model and Australian tax treaties.
LAWS6946 Tax Treaties Special Issues

Credit points: 6 Teacher/Coordinator: Prof Richard Vann Session: Intensive November Classes: Oct 14-16 & 19-20 (9-3.30) Assumed knowledge: As this is an advanced unit, it is assumed that students undertaking this unit have successfully completed LAWS6177 Tax Treaties Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This advanced unit considers specialised topics in the area of tax treaties, largely reflecting the work of the OECD and United Nations on tax treaties currently and in the last decade, particularly the OECD/G20 project on Base Erosion and Profit Shifting (BEPS). Topics covered include OECD and UN policy development processes, high value services and the digital economy, transfer pricing, harmful tax practices, treaty abuse, non-discrimination, entities and tax treaties (especially partnerships and collective investment vehicles), transparency and assistance in collection, dispute resolution, and the BEPS multilateral instrument. Upon completion of this unit, students will have a detailed understanding of the current driving forces and issues in the development of tax treaties and other international tax standards.
LAWS6125 Taxation of Corporate Finance

Credit points: 6 Teacher/Coordinator: Mr Paul O'Donnell Session: Semester 1 Classes: 1x2-hr lecture/week. First class commences on starts Thu 20 Feb 2020. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax and LAWS6030 Corporate Taxation before enrolling in this unit. Assessment: classwork (30%) and 2hr exam or 7000wd essay (70%) Mode of delivery: Normal (lecture/lab/tutorial) evening
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This advanced unit will analyse the current law on the tax treatment of the principal forms of raising corporate finance from sources both in Australia and offshore, in Australian and foreign currencies, and of hedging the various exposures that a taxpayer may have from of its fund-raising and investments. The unit will consider the taxpayer's position both within and outside the TOFA regime. Common forms of innovative financial instruments will be examined, including debt, equity and hybrid instruments, forward and futures contracts, derivative instruments, and various asset-based forms of corporate financing. Selected non-resident withholding tax issues will be examined.
LAWS6244 Taxation of Corporate Groups

Credit points: 6 Teacher/Coordinator: Prof Richard Vann Session: Intensive October Classes: Sep 16-18 & 21-22 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This advanced unit examines the policy and practical issues that arise in the tax consolidation regime in Australia. The unit covers: policy and history of grouping and consolidation; entry into consolidation; effects of consolidation; exit from consolidation; losses, imputation and tax payments in consolidation; international rules in consolidation including MEC groups; restructures of consolidated groups and application of anti-avoidance rules to consolidate groups.
LAWS6118 Taxation of Partnerships and Trusts

Credit points: 6 Teacher/Coordinator: Prof Richard Vann Session: Semester 2 Classes: 2x2-hr lecture/week. Classes are held every Mon and Thu 6-8pm. First class commences on Thu 23 Jul and concludes on Thu 10 Sep 2020. Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Normal (lecture/lab/tutorial) evening
Note: Academic Profile https://sydney.edu.au/law/about/people/list.php. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This advanced unit examines the policy and practical issues that arise in Australia for the taxation of income derived through partnerships and trusts which are generally transparent for tax purposes, with a twofold focus: first for private business and investment; secondly for collective investment. The unit covers: problems and policies for taxing entities (partnerships and trusts contrasted with companies); classification of entities for tax purposes; taxation of partners and trust beneficiaries in a private business/high wealth context; taxation of collective investment vehicles mainly in the form of trusts and partnerships, including Attribution Managed Investment Trusts, Corporate Collective Investment Vehicles, Managed Investment Trusts, listed investment companies, public trading trusts, limited partnerships, venture capital, foreign hybrids, and investment manager regime.
LAWS6336 Taxation of Real Property Transactions

This unit of study is not available in 2020

Credit points: 6 Teacher/Coordinator: Assoc Prof Celeste Black Session: Semester 2 Classes: 1x2-hr lecture/week. First class starts on Jul 30 (6-8pm). Assumed knowledge: It is assumed that students undertaking specified tax units have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian taxation law in a law or accounting practice, in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience, they first should undertake LAWS6825 Introduction to Australian Business Taxation before enrolling in this unit. Assessment: class assessment (30%) and take-home exam (70%) Mode of delivery: Normal (lecture/lab/tutorial) evening
Note: Academic Profile https://sydney.edu.au/law/about/our-people.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/cpd/
This unit will exam they key aspects of the application of taxes to real property transactions. The unit will commence with an introduction to the tax policy considerations relevant to the taxation of real property. The application of taxes to real property transactions will then be considered. In addition to focussing on the acquisition, development, sale, and leasing of real property, the unit will consider tax issues for the development of commercial, residential, hotel/serviced apartment complexes, and retirement villages. Practical case studies will be used to draw out the impact of income tax, GST, stamp duty (primarily NSW), and land tax on real property transactions.
Textbooks
Thomson Reuters Fundamental Tax Legislation 2018 or equivalent
LAWS6123 Transfer Pricing in International Tax

Credit points: 6 Teacher/Coordinator: Ms Melissa Ogier Session: Intensive June Classes: May 20-22 & 25, 26 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have an understanding of Australian income taxation law commensurate with that which would be obtained from completing undergraduate study in Australian taxation law or five years working with Australian tax law in a law or accounting practice in an industry role or in the Australian Taxation Office. For students who do not have such knowledge or work experience they first should undertake LAWS6825 Introduction to Australian Business Tax before enrolling in this unit. The completion of LAWS6209 Australian International Taxation will provide students; without such knowledge or work experience; with additional knowledge and skills that will assist in successfully completing this unit. Assessment: in-class test (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
The unit examines transfer pricing law and practice in Australia and globally. Transfer pricing continues to be rated by tax directors as the number one international tax issue they face. The release of the revised OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in 2010 and the ongoing projects, the rewrite of the Australian transfer pricing legislation, and the substantial transfer pricing rulings program of the Australian Taxation Office, have together significantly increased the international and Australian materials available on the law and practice in transfer pricing. Students will gain an understanding of the policy, and detailed application of transfer pricing rules within Australia and an understanding of the international framework.
LAWS6109 UK International Taxation

Credit points: 6 Teacher/Coordinator: Prof Malcolm Gammie Session: Intensive October Classes: Sep 23-25 & 28-29 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have successfully completed an undergraduate/postgraduate unit of study in tax law. Assessment: class assessment (20%) and take-home exam (80%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
This unit covers the domestic provisions of UK direct tax law dealing with international transactions, as well as UK treaties and the impact of EU law on the UK tax system. The UK remains one of Australia's major trading partners. UK taxation thus has significant effects for inbound and outbound investment between Australia and the UK. This unit will be of interest to tax professionals who have dealings with the UK. The objective of the unit is to provide an overview of the UK tax system focusing on cross-border investment and expatriate employment issues and a detailed analysis of the most important legislative and treaty rules of the UK in the international direct tax area, especially in dealings with Australia. Upon successful completion of the unit, participants will have an advanced understanding of the policies of the UK rules for taxing international transactions as well as a detailed knowledge of the principles of company and personal taxation applicable to inbound and outbound transactions in the UK. The unit includes a study of: 1. Overview of the UK tax system; 2. Taxation of inbound investment in the UK; 3. Taxation of outbound investment in the UK; 4. Transfer pricing in the UK; 5. UK tax treaties including the Australia UK Tax Treaty; 6. EU tax law as it affects the UK.
LAWS6171 US International Taxation

Credit points: 6 Teacher/Coordinator: Prof Ethan Yale Session: Intensive May Classes: Apr 29, 30 & May 1, 4 & 5 (9-3.30) Assumed knowledge: It is assumed that students undertaking this unit have successfully completed an undergraduate/postgraduate unit of study in tax law. Assessment: in-class assessment (30%) and 2hr exam (70%) Mode of delivery: Block mode
Note: Academic Profile https://sydney.edu.au/law/about/our-visitors.html. The unit is also available on a Continuing Professional Development basis https://sydney.edu.au/law/study-law/continuing-professional-development.html
The object of this unit is to provide an overview of the income tax system of the US with a focus on the most important legislative and treaty rules of the US in the international income tax area, especially in dealings with Australia. The unit will examine both the policies behind the US taxation of international transactions as well as the rules and principles of income tax law applicable to inbound and outbound transactions in the US.
Master of Taxation
The following units are available to Master of Taxation students only
LAWS6147 Independent Research Project

Credit points: 6 Teacher/Coordinator: Supervised by an appointed Sydney Law School academic staff member Session: Semester 1,Semester 2 Assessment: 8000 to 10,000wd research project (100%) due on 15 June (Semester 1) or 15 November (Semester 2) Mode of delivery: Supervision
Note: Department permission required for enrolment
Note: Applications close on 30 November (Semester 1) and 30 May (Semester 2). Applications should only be lodged after the completion of at least 24 credit points. Late applications may be accepted from those with incomplete results For further information, please visit https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-research-projects#research-projects or contact E: law.postgraduate@sydney.edu.au
The goal of this unit of study is to provide students with an opportunity to pursue advanced research in an area of their choosing, under the limited supervision of a School member. The unit is only available in special circumstances, and with the approval of the relevant Program Coordinator.
LAWS6182 Independent Research Project A

Credit points: 6 Teacher/Coordinator: Supervised by an appointed Sydney Law School academic member Session: Semester 1,Semester 2 Corequisites: LAWS6183 Assessment: 15,000 to 20,000wd research project (100%) due on 15 June (Semester 1) or 15 November (Semester 2) of the final semester in which a student is enrolled in the research project Mode of delivery: Supervision
Note: Department permission required for enrolment
Note: Applications close on 30 November (Semester 1) and 30 May (Semester 2). Applications should only be lodged after the completion of at least 24 credit points. Late applications may be accepted from those with incomplete results. Students must complete both LAWS6182 and LAWS6183 within one or over two semesters. For further information, please visit https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-research-projects#research-projects or contact E: law.postgraduate@sydney.edu.au
The goal of this unit of study is to provide students with an opportunity to pursue advanced research in an area of their choosing, under the limited supervision of a School member. The unit is only available in special circumstances, and with the approval of the relevant Program Coordinator.
LAWS6183 Independent Research Project B

Credit points: 6 Teacher/Coordinator: Supervised by an appointed Sydney Law School academic staff member Session: Semester 1,Semester 2 Corequisites: LAWS6182 Assessment: 15,000 to 20,000wd research project (100%) due on 15 June (Semester 1) or 15 November (Semester 2) of the final semester in which a student is enrolled in the research project Mode of delivery: Supervision
Note: Department permission required for enrolment
Note: Applications close on 30 November (Semester 1) and 30 May (Semester 2). Applications should only be lodged after the completion of at least 24 credit points. Late applications may be accepted from those with incomplete results. Students must complete both LAWS6182 and LAWS6183 within one or over two semesters. For further information, please visit https://canvas.sydney.edu.au/courses/4533/pages/postgraduate-coursework-research-projects#research-projects or contact E: law.postgraduate@sydney.edu.au.
Please refer to LAWS6182 Independent Research Project A.