International Tax

• Semester: Fall 2021
• Course ID: 393F
• Credit Hours: 3
• Unique: 29635

Description

Same as LAW 374R, 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

Required Textbooks:

(1) Robert J. Peroni, Karen Brown & J. Clifton Fleming, Jr., Taxation of International Transactions: Materials, Text, and Problems (5th ed. 2021) —will be published in early to mid July 2021—new edition must be ordered

(2) International Income Taxation—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2021-2022 ed.)—will be published in early to mid July 2021—new edition must be ordered

Recommended Textbooks (Optional);

(1)  Mindy Herzfeld, International Taxation in a Nutshell (12th ed. 2020)—ISBN 978-1-68467-346-9

(2) Joseph Isenbergh & Bret Wells, International Taxation (West Academic/Foundation Press 4th ed. 2020) (Concepts and Insights Series)—ISBN 9781684673636