5387 International Tax - WELLS- 11800
Bret Wells (FACULTY)
Course Areas: Taxation
Time: 6:00p-7:30p MW Location: 209 BLB
Course Outline: This course provides a comprehensive analysis of the two most important fundamental areas of the U.S. income taxation system relevant to cross-border transactions: i) How does the United States tax non-resident aliens and foreign corporations on their income derived from U.S. sources? and, ii) How does the United States tax U.S. persons and U.S. corporations on the income which they receive from sources outside the United States? Specific topics to be covered will include: a) Taxation of U.S. citizens and enterprises organizing businesses and realizing income in foreign locations, including the use of the foreign tax credit and the taxation of tax haven based income b) U.S. and foreign income tax treatment of export and import income c) The possible economic reallocation of income and deductions between U.S. enterprises and related foreign enterprises d) Taxation of (i) foreign portfolio income realized by foreigners in the U.S., (ii) foreign businesses deriving income in the United States and (iii) gains from foreign investment in U.S. real estate; and (e) Foreign currency transactions.
Prerequisites: Yes Federal Income Tax is a prerequisite for enrollment in this course.
First Day Assignments: Please read the Gustafson casebook pages 1 through 75. Also, before the first day of class, please watch in full the two Senate Finance hearings that are at the following two links: Senate Finance Hearing: Tax Reform Options: International Issues (September 8, 2011) and Senate Finance Hearing: International Tax Reform (October 3, 2017)
Final Exam Schedule: 05/09 6-9pm 211 TU2
This course will have:
Satisfies Skills Course Requirement: No
Satisfies Senior Upper Level Writing Requirement: No
Experiential Course Type: no
Bar Course: No
Course Materials (10/10/2017 12:41:37 PM)
Course Materials: 3 items: a. Gustafson, Peroni & Pugh, “Taxation of International Transactions – Materials, Text and Problems, 4th Edition (2011)” ISBN: 9780314911711; b. International Income Taxation: Code & Regulations Selected Sections 2017-2018 edition is ISBN: 9780808046349; c. Additional materials provided by Professor.