Course Description

LAWS 7617
International Taxation
General Description:
Deals with the basics of U.S. income taxation of international activities, in the context of U.S. persons doing business abroad and foreign persons doing business in the U.S. The principal focus is on interpretations of the Internal Revenue Code and the U.S. Model Income Tax Treaty. Coverage includes exclusion for foreign earned income, transfer pricing, controlled foreign corporation provisions, foreign tax credit rules, branch profits tax and inbound business structures, and investment in U.S. real estate by foreign investors. Subject to overall class size, four memoranda addressing selected problems of international taxation typically supplant a final examination. Prerequisite: Income Taxation, LAWS 6007.

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