Intl Business Taxation (LAW-624-001)
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An introduction to U.S. taxation of U.S. and foreign persons engaged in cross-border business activities. Topics include U.S. jurisdiction to tax, tax treaties, allocation of income, transfer pricing, "earnings stripping" and other base erosion payments, distribution of profits by non-U.S. subsidiaries, and foreign tax credits. We will discuss the changes pertaining to U.S. international tax rules under the TCJA (Tax Cuts and Jobs Act) of 2017, and changes in international tax policy within the OECD Base Erosion and Profit Shifting framework including the digital economy. 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 which most frequently arise. The course study will include problem-solving, addressing at a foundational level key issues facing U.S. "inbound" and "outbound" business transactions.
Textbooks and Other Materials
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First Class Readings
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