International Tax

Catalog description

This course introduces the U.S. federal law that governs the income taxation of U.S. taxpayers in respect of income from sources or activities outside the United States as well as the income taxation of foreign taxpayers in respect of U.S.-related income. It presents the distinct U.S. income tax regimes applied to U.S. taxpayers and foreign taxpayers, and on the rules determining the principal determinants of tax liability under these regimes, namely, residence (of an individual or an entity) and source (of income). In this context, it discusses the following topics: the tax classification of U.S. and foreign entities, the problem of double taxation and its remedies (principally through the mechanism of foreign tax credit), the role and structure of tax treaties, transfer pricing, anti-deferral U.S. income tax regimes (such as under Subpart F of the Code) and anti-tax-avoidance regimes (such as under Code Section 367). Prerequisite(s): LAW 7601 .