LAW 7880 - U.S. Taxation of International Income

Prerequisite: Federal Income Tax - LAW 7133. An introduction to the U.S. taxation of international transactions, with consideration of policy and jurisdictional issues involved in the U.S. international tax laws and the U.S. tax treaty network. Topics covered will include source of income rules, taxation of foreign persons with passive U.S. investments, taxation of foreign persons operating a U.S. trade or business, taxation of foreign-owned U.S. real property interests, the branch profits tax, and the effect of U.S. tax treaties on such “inbound” transactions. The course will also cover the U.S. taxation of worldwide income of U.S. citizens and residents, including the U.S taxation of “outbound” transactions (foreign activities of U.S. persons), the recent changes to U.S. taxation of foreign subsidiaries of U.S. parent companies, the effect of U.S. tax treaties, and the foreign tax credit mechanism. 3 credits.