International Tax

Course Information

Registration Information

Meeting Times

Day Time Location
TUE 3:45 - 5:35 pm TNH 3.126

Evaluation Method

Type Date Time Location
Final December 15, 2018 8:30 am A-Z in 3.126
Paper

Description

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. 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

Textbooks ( * denotes required )

Taxation of International Transactions *
Gustafson, Peroni & Pugh
West Academic , edition: 4th
International Income Taxation--Code and Regulations--Selected Sections *
Robert J. Peroni, coord. ed.
Wolters Kluwer/CCH , edition: 2018-2019

Instructors

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