This course examines the current outbound international tax rules, but will demonstrate that the law in this area is more than a collection of those rules. It is instead a process, ever evolving, to address its various contexts and constituencies. We will examine the relevant contexts -- Constitutional, international (WTO, OECD) and commercial -- and will engage in class discussions applying the rules within those frameworks. The objective is for students to gain enough grounding in the rules to start a path toward mastery, and to understand the drivers behind the rules so that students can apply them as they exist today, and analyze changes as they occur in the future. Pre or co- requisite: Tax Aspects of International Business (recommended)

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