Course Detail
Course Components:
This course covers the major international tax issues relating to inbound investment (i.e., investment and business activity in the United States by non-U.S. persons) and outbound investments (i.e., investment and business activity by U.S. persons outside the United States). Coverage includes residence, business, and investment activity of foreign persons in the U.S., the foreign tax credit, interest, and expense allocation, transfer pricing, controlled foreign corporation, and dividend exemption rules. Attention to the interaction of U.S. domestic law and bilateral income tax treaties will be considered throughout. Students will draft four memoranda (each memo must exceed 1,000 words) or the equivalent writing project on tax law in general, international tax, or tax policy issues.