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. 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 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;
• Treaty shopping and tax arbitrage;
• International tax administration; and
• The future of the international tax regime.
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 email@example.com
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 International Taxation in a Nutshell, by Richard L. Doernberg, Tenth Edition, West, 2016, ISBN #9781628105551. This book can be purchased from the campus bookstore. It is also available in an inexpensive Kindle edition from Amazon.
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 are Taxation of International Transactions, by Gustafson, Peroni, and Pugh, Fourth Edition, 2011 and International Taxation by Joseph Isenbergh, Third Edition, 2012. Both contain an in-depth discussion of international tax rules.
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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