Course Description

We will consider the role of an American lawyer acting as tax planner in context of transnational business transactions; U.S. income tax consequences of foreign corporations and individuals doing business and investing in the U.S.; and U.S. income tax consequences of American companies and individuals doing business and investing in foreign countries.

Additional Requirements for Graduate Students:
Graduate law students will not be doing any extra work beyond that required of the Juris Doctor students. J.D. students are post-baccalaureate students and the workload expected of them is the same workload expected of post-baccalaureate graduate students.

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Athena Title

International Taxation

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Undergraduate Prerequisite

JURI 5120/7120 or JURI 5120E/7120E

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Graduate Prerequisite

JURI 5120/7120 or JURI 5120E/7120E

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Semester Course Offered

Offered every year.

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Grading System

A - F (Traditional)

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Student learning Outcomes

• By the end of this course, students will be able to identify the tax rules that are relevant to a given international tax problem.
• By the end of this course, students will be able to interpret those rules and analyze the tax consequences of the given problem in light of them.
• By the end of this course, students will be able to analyze those rules in light of the facts.
• By the end of this course, students will be able to provide the client with a legal conclusion and/or advice for addressing the client's goals in light of the legal analysis.

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Topical Outline

• Source rules
• foreign persons’ trade or business income
• Foreign persons’ non-business income
• Anti-deferral regimes
• The foreign tax credit

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