Description: This course is an introduction to the principal elements of the U.S. taxation of international transactions. The first part of the course will address the way in which individual and corporate foreign taxpayers are taxed in the United States. The second part will deal with the way in which U.S. individual and corporate taxpayers are taxed on income earned in other countries. The impact of tax treaties will be addressed in both parts of the course.
In lieu of an exam, students will prepare a memorandum for each part of the course regarding the tax consequences of specified international situations and transactions. Several weeks will be allowed for the preparation of each of these assignments, which take the form of memoranda to a senior partner in a law firm rather than law review articles.
Prerequisite: Income Taxation I
With professor permission, meets the WIE requirement.