International Tax

Catalog description

Provides a basic understanding of principles related to U.S. taxation of foreign income and foreign taxpayers. Students will study U.S. cross-border tax rules by analyzing primary source materials (e.g., U.S. Internal Revenue Code, Treasury Regulations, IRS Publications, U.S. Income Tax Treaties etc.) and editorial analysis (e.g., tax practitioner commentary). Topics to be discussed may include U.S. taxation of outbound foreign investment (U.S. taxation of US taxpayers’ foreign income) and inbound investment (U.S. taxation of foreign taxpayers’ U.S. income). Concepts include sourcing of income, foreign tax credits and limitations, withholding tax, effectively connected income, and the role of income tax treaties.