International Tax

Catalog description

This course is designed to provide an overview of common international tax planning issues in which the U.S. tax system asserts taxing jurisdiction over cross-border activities and will focus on: a) Inbound Taxation: the U.S. taxation of non-resident aliens and foreign corporations with respect to their activities conducted within the territory of the United States; and b) Outbound Taxation: the U.S. taxation of U.S. persons with respect to their activities conducted outside the territory of the U.S. Major subjects will include relevant provisions included in the Internal Revenue Code and in U.S. income tax treaties, sourcing rules for allocating income and deductions among several national taxing jurisdictions, extra-territorial taxation of U.S. citizens and enterprises realizing income in foreign locations (including the mechanics of the U.S. foreign tax credit), income tax incentives for exports, reallocation of income and deductions between U.S. and related foreign enterprises (i.e., transfer pricing), taxation of foreign persons with respect to their income derived from U.S. portfolio investments, from U.S. trade or business activities, and from U.S. real property investments.