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).

Additional Information:
Credit Hours: 3
Grading Option: Numeric Grade and ONE-Time Pass Option is Available, or Letter Grade Only
Graduation Writing Requirement: No
Flexible/Upper-Level Writing Requirement: No
Skills Requirement: No
Simulation Course: No
Experiential Learning: No
Seminar: No
Prerequisite: Federal Income Taxation
Special Withdrawal Course: No
Final Exam Given: Yes
Final Exam Type: In-Class - Completely Secure
Attendance Policy: Per Statement Of Student Policies

* The law school has a policy that is used to calculate credit hours. Please see the Statement of Student Policies.