International Tax I

LAW TX 962

This course provides an overview of U.S. international taxation as it affects both individuals and corporations. Lectures and discussions will examine how U.S. tax law addresses both inbound (non-U.S. persons) and outbound (U.S. persons) taxpayers / transactions. Among the specific topics to be addressed are the structure of U.S international taxation ("worldwide" v. territorial taxation), U.S. anti-deferral regimes (controlled foreign corporation and passive foreign investment company rules), and mechanisms to ameliorate double taxation (tax treaties, the Sec. 911 exclusion, the foreign tax credit). Course readings will include primary sources of U.S. tax law as well articles and commentary on U.S. international tax policy. While not a primary objective of International Tax I, upon completion of the course students should be able to impress their friends at cocktail parties by being able to explain in exacting detail how Apple, Google and others achieve their often enviable effective tax rates.