International Tax

• Semester: Fall 2023
• Course ID: 393F
• Credit Hours: 3
• Unique: 29475

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, 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. Because class enrollment is limited to 14 students, the Law School's grading curve will not apply (except that A+ grades are limited to no more than 6% of the students in the course, rounded up to the next whole number, meaning that only 1 A+ is allowed in the course). 

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) 

(2) International Income Taxation—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH, 2023-2024 edition)

Recommended Textbooks (Optional):

(1)  Mindy Herzfeld, International Taxation in a Nutshell (West Academic, 13th edition, 2023)

(2) Joseph Isenbergh & Bret Wells, International Taxation (West Academic/Foundation Press, 2022 edition) (Concepts and Insights Series)