Tax: Federal Taxation of International Transactions

Course Number:

Credit Hours:
3 Credit Hours

Prerequisites: RCC*; Tax I (LAW 607). This course examines the U.S. Federal Income Taxation of both inbound transactions (the U.S. income tax consequences of business and investment activities in the U.S. by foreigners) and outbound transactions (the U.S. income tax consequences of foreign business and investment activities by U.S. taxpayers). It will examine, in particular, (1) the jurisdictional rules regarding the right to tax income in the international context, (2) the “source” rules (domestic or foreign) for income and deductions, (3) the foreign tax credit, (4) problem of “deferral” of foreign income earned by subsidiaries of U.S. parents, and (5) the U.S. tax consequences of using foreign currency.

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