International Business Taxation (LAW-624-001)
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, email@example.com.
An introduction to U.S. taxation of U.S. and foreign persons engaged in international activities. Topics include U.S. jurisdiction to tax, the international tax regime including the OECD and Base Erosion and Profit Shifting (BEPS) initiative, tax treaties, “treaty shopping” and tax arbitrage, allocation of income, transfer pricing, deferral of foreign earnings and profits by US-based companies, foreign tax credits, etc. We will discuss the US legislative changes pertaining to international tax rules under the Tax Cuts and Jobs Act of 2017. The goal of the class is to provide an overview of the relevant law, giving due respect to its complexity and the policies underlying it, and to identify and tackle the types of issues and problem solving that most frequently arise.
Textbooks and Other Materials
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First Class Readings
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