SLN #: 17783
Course Prefix: LAW-691
Course Section: 018
Credit Hours: 3
This course provides an introduction to the U.S. aspects of international taxation. Although international taxation was once the province of only a small number of tax practitioners, globalization now requires that every tax attorney have at least some familiarity with the United States’ approach to taxing international transactions.
The first part of the course will examine how the United States taxes foreign persons on the income they derive from U.S. sources. The second part addresses a more complex topic – the taxation of U.S. persons on their worldwide income. We will examine residency rules, source rules regarding income and deductions, the branch profits tax, and the extent to which U.S. bilateral tax treaties modify the U.S. legislation.
Problems that are intended to illustrate the operation of the Code and regulations will be assigned for most classes, and we will spend a significant amount of our class time solving those problems.
Federal Income Taxation is a prerequisite for the course. Business Organizations or Corporate Taxation would be helpful, but is not required.
The casebook for this course is TBD. Lexis Nexis and Foundation Press each have International Tax books coming out this fall (priced at $125.00 and $166.00, respectively), and I will review each to determine which will best suit the course.
Also, you will need to purchase a statutory supplement
that contains the key international tax provisions
(available from Foundation Press for about $35.00).
Credit Hours: 3
Grading Option: Numeric Grade and ONE-Time Pass Option is Available, or Letter Grade Only
Graduation Writing Requirement: No
Flexible Writing Requirement: No
Skills Requirement: No
Prerequisite: Federal Income Taxation
Final Exam Given: Yes
Final Exam Type: In-Class
Attendance Policy: Per Statement of Student Policies