LAW - 624 International Business Taxation

(3 hrs.)

An introduction to U.S. taxation of U.S. and foreign persons engaged in international activities. Topics include U.S. jurisdiction to tax, tax treaties, allocation of income, transfer pricing, foreign tax credits, etc. We will discuss the recent changes in legislation pertaining to U.S. international tax rules under the JOBS Act of 2004. The goal of the class is to provide an overview of the relevant law, giving due respect to its complexity and the policies underlying it, and to identify and tackle the types of issues that most frequently arise.