International Taxation

Catalog description

This course examines the federal income tax treatment of international transactions. It will focus on the principles and policies underlying the United States tax system as it relates to income earned by U.S. citizens and residents doing business and investing outside the country, as well as income derived from foreign persons doing business and investing in the United States. Topics include jurisdiction issues, source of income rules, effectively connected income, FDAP income, the foreign tax credit, the role of tax treaties in international tax, and an introduction to subpart F and other anti-deferral mechanisms. Credit Hour : 1-3 Recommended: LAW 5375 Basic Federal Income Taxation