5387 International Tax - STRENG- 12993
William Streng (FACULTY)
Course Areas: Taxation
Time: 7:30p-9:00p MW Location: 215 TU2
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.
Course Notes: The casebook for International Tax (Gustafson, et.al., West Publishing) will not be available when class starts but the publisher has made available a PDF of Chapters 1 and 2 for students usage until the book becomes available.
Please go to http://www.law.uh.edu/faculty/wstreng/ to access the pdf.
Prerequisites: Yes Federal Income Tax is a prerequisite for enrollment in this course.
First Day Assignments:
Final Exam Schedule: 05/04 9am-noon 213 BLB
This course will have:
Satisfies Skills Course Requirement: No
Satisfies Senior Upper Level Writing Requirement: No