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 and the various anti-deferral regimes (principally Subpart F). Throughout, the course examines the relevant U.S. domestic law and treaty provisions. The grade for the course will be based on a final, open book examination. Three Units.
Prerequisite: Federal Income Tax.
Peroni, Robert J.