International Tax

This course examines the U.S. income tax laws and policies relating to the taxation of foreign persons' investment or business activities in the United States ("inbound") and U.S. persons' direct or indirect investment or business activities in other countries ("outbound"). After an introductory overview, it addresses the taxation of inbound activities, covering, principally, the topics of residence, the source of income and deductions, the taxation of investment activities (including portfolio investment and real estate investment), and the taxation of U.S. business activities of foreign persons. The subsequent consideration of the taxation of outbound activities concentrates primarily on the foreign tax credit system, the 100% deduction for certain foreign-source dividends received by a U.S. corporation from a foreign corporation, and the various anti-deferral regimes (principally the rules for Subpart F income and global intangible low-taxed income ("GILTI")) that apply to certain U.S. shareholders of foreign corporations. Throughout, the course examines the relevant U.S. domestic law and treaty provisions. If class enrollment is more than 9 students but fewer than 21 students, the grade for the course will be based 50 percent on a final examination and 50 percent on a tax policy paper, and the curve will not apply. If class enrollment is under 10 students, the grade will be based entirely on a final examination and the curve will not apply.  Prerequisite: Federal Income Tax


Class Details

Meeting Days Time Location
Monday, Tuesday 3:45 - 5:00 pm TNH 3.114
Exam Type Date Time Alpha Range Room
Final 12/18/19
Paper

Additional Information

Course Type
Grading Method
Pass/Fail Not Allowed
Will use floating mean GPA if applicable

Textbooks

  • Taxation of International Transactions - Gustafson, Peroni & Pugh
      West Academic , edition: 4th
      ISBN: 978-0314911711   (required)
  • International Income Taxation--Code and Regulations--Selected Sections - Robert J. Peroni, coord. ed.
      Wolters Kluwer/CCH , edition: 2019-2020
        (required)