Fall 2012 Course Schedule

U.S. International Taxation (LAW-624-001)


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This course describes the U.S. taxation of U.S. and foreign persons engaged in international activities. Topics include nationality, residence, and U.S. jurisdiction to tax; the allocation of income and deductions between taxing jurisdictions; the taxation of the U.S. income of foreign taxpayers; the taxation of the foreign income of U.S. taxpayers, including the foreign tax credit; the role of tax treaties; tax deferral, transfer pricing, and treaty shopping; international tax administration; and the future of the international tax regime. The goal is to provide an overview of the relevant law and to identify and analyze the practical issues that most frequently arise in the international tax arena.
This is an advanced tax course which assumes that students are already familiar with the basic legal rules relating to income taxation. Students enrolling in the course should already have taken at least one income tax course, either in the U.S. or in their home country. Students without such preparation should not enroll in this course unless they have requested permission from the instructor at tom@tomfield.net.

Textbooks and Other Materials

The textbook information on this page was provided by the instructor. Students should use this information when considering purchases from the AU Campus Store or other vendors. Students may check to determine if books are currently available for purchase online.

The textbook for the course is International Taxation, by Joseph Isenbergh, Third Edition, Foundation Press, 2010, ISBN 978-1-59941-441-6.
This book can be purchased from the campus bookstore in Butler Pavilion (phone 202-885-6301) or by going to www.follett.com. When you reach that site, access “textbooks” and American University WCL) law course 624, section 001.

Additional required course readings for each class are posted for “U.S. Intl Taxation (624-001)” in the course database on MyWCL.

Recommended supplemental background reading is Taxation of International Transactions, by Gustafson, Peroni, and Pugh, Fourth Edition, 2011. This book is on reserve in the library.

You will also need access (either online, in print, or in the library) to a copy of the U.S. Internal Revenue Code and the U.S. Treasury Regulations on Income Tax.

First Class Readings

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