International Tax II
LAW TX 939
This course will examine in some detail two fundamental but most important areas of the U.S. taxation of U.S. corporations' foreign operations. This course is designed for those students who are interested in practicing in the international tax area or who are interested in exploring in considerable detail two on the Internal Revenue Code's more complex statutory regimes. This course will include an in-depth analysis of the rules relating to the foreign tax credit, including basic sources of income and allocations of deductions (particularly, interest expense), with emphasis on the determination of the deemed paid credit, the overall and separate limitations and the look-through and foreign loss rules. The second part will address in detail the anti-deferral provisions under Subpart F of the IRC, including the definition of U.S. shareholder and controlled foreign corporation, the determination of the various types of subpart F inclusions, and the effect of partnership and disregarded entities on the application of these rules. Notes: Limited enrollment. Grade based on a mid-term examination, a final examination, and class participation.