Required Texts

(1) Taxation of International Transactions by Gustafson, Peroni, & Pugh (Thomson West 4th ed. 2011) ISBN 978-0-314-91171-1. In addition, as soon as I receive it from the authors, I will make available a supplement that incorporates all of the many changes to the international provisions incorporated in the Tax Cuts and Jobs Act, enacted in late December 2017.

(2) Access to the Internal Revenue Code & Regulations. In class, I shall be using Selected Sections, United States International Taxation (Foundation Press 2018 ed.) ISBN 978-1-64020-822-3. For those who prefer online access rather than a hard copy in class, you can type the code section (e.g., IRC 61) or treasury regulation (e.g., TR 1.61-2) into your browser’s search box, and the first item to come up will be the Legal Information Institute’s version of the code section or regulation. The LII is hosted by Cornell law school, and it is the source that I used for the hyperlinks in my e-textbook for the Tax I course.

You will not be able to access the internet or your hard drive during the final exam, however, so those of you choosing online access may wish to print out some of the Code sections and Treasury Regulations that you wish to have with you during the final exam. (That’s one advantage of having the hard copy of the Code and Regs.)

Optional Text

I usually do not recommend that students waste money on optional student treatises. Nevertheless, this year may be the exception that proves the rule for this particular course. The Tax Cut and Jobs Act changed Code sections applying to cross-border transactions—particularly outbound transactions—in fundamental ways. While the authors of your textbook have written a supplement pertaining to the many TCJA changes while they work on the next edition of the textbook (which will more seamlessly incorporate the TCJA changes), I know from experience that a supplement is not ideal. The Nutshell listed below, in contrast, fully incorporates the changes made by the TCJA in the narrative, so if you are having particular difficulty in incorporating the supplement material into the textbook proper, the Nutshell may be a help to you. I shall not assign material from the Nutshell, but those students who buy it can read the corresponding pages covering a particular topic as a supplement to the required textbook (and its supplement).

International Taxation in a Nutshell by Herzfeld and Doernberg (West 2018) ISBN 978-1-64020-905-3.

First Class Assignment

I provide the first class assignment below. For those who wish to prepare more, I attach the syllabus here, though I shall distribute a hard copy in the first class.

Read pages 1-41.