Intl Business Taxation (LAW-624-001)
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This course covers the U.S. taxation of U.S. and foreign persons engaged in cross-border activities. 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. Topics include:
- Nationality, residence, and U.S. jurisdiction to tax;
- The source of income and the allocation of deductions between taxing jurisdictions;
- The taxation of the U.S. non-business and business income of foreign taxpayers;
- The taxation of the foreign income of U.S. taxpayers, including the deferral and the foreign tax credit;
- The role of tax treaties;
- Transfer pricing;
- Treaty shopping and tax arbitrage;
- International tax administration and anti-avoidance;
- The future of the international tax regime: territorial versus worldwide taxation;
- Key international provisions of the 2017 Jobs Creation and Tax Act (JCTA) including "BEAT", Section 965 Deemed Earnings Repatriation, "GILTI", and "FDII"; and
- Global tax policy harmonization through the OECD Inclusive Framework countries, the BEPS (Base Erosion and Profit Shifting) actions, and Taxation of the Digital Economy.
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 required textbook for this class is U.S. International Taxation, by Avi-Yonah, Ring, Brauner, & Wells, 5th Ed., Foundation Press/West Publishing, 2022 (ISBN: 978-1-64708-229-1). This book can be purchased from the campus bookstore. 15% Discount available from westacademic.com as per publisher rep:
- 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. For convenience I have asked the campus bookstore to order the following: Selected Sections, United States. International Taxation 2022 Edition by Daniel J. Lathrope (Foundation Press). (ISBN: 9781636599601)
“ New Discount Update:
I am happy to offer your students a 15% discount and free ground shipping off of the print we are now extending this same offer off our e-Books. Students will need to create an account and place an order directly through us at www.westacademic.com They will receive this discount by using the promo code: HESTUDENT”
Personal Note: Based on my tax lawyer career (and former law student) experience, I highly recommend access to a print version of the relevant U.S. IRC and Treasury Regulation sections as this will better facilitate your ability to work through and solve the various tax problems and more readily apply the law and regulations.
Any supplemental course readings and problems for each class will be posted for “U.S. Intl Taxation (250-001)” on Blackboard.
Recommended, optional and supplemental reading:
Isenbergh and Wells's International Taxation, 4th Edition Foundation Press 2020 (Concepts and Insights Series) ISBN: 9781684673636; and International Taxation in a Nutshell, by Mindy Herzfeld, 12th Edition, West Academic, 2020 ISBN: 9781684673469. Both contain an in-depth discussion of international tax rules which will supplement the Avi-Yonah, et. al. Text material. (You will not be tested on anything not covered in class and not in the primary Text reading material, including anything “accretive” which might be contained in the supplemental materials.)
First Class Readings
Read Ch.1, pp. 25-34
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