Fall 2024
Professor(s):
Bret Wells (FACULTY)
Credits: 3
Course Areas: Taxation
International Law
Time: 1:00p-2:30p MW Location: 221
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 Syllabus: Syllabus
Course Notes: (Face-to-Face) The UH registration system instruction mode for this course is listed in parenthesis. For this instruction mode, instructors and students are expected to normally be physically present in the classroom. If the course has a final examination, it will be in a classroom requiring your physical presence. Other assessment, such as a mid-term exam, may also be in a classroom. Whether this instructor will offer “remote presence” (starting a zoom meeting from the podium computer to enable student remote access on an occasional basis) for part or all of the semester is not known, but students should not rely on an expectation that remote presence will be available..
Prerequisites:
First Day Assignments:
Final Exam Schedule: 12/10/20241-4pm 310
This course will have:
Exam:
Paper:
Satisfies Senior Upper Level Writing Requirement: No
Experiential Course Type: No
Bar Course: No
DistanceEd ABA: No
Pass-Fail Student Election: Available
Course Materials
Book(s) Required
Course Materials: a) Reuven S. Avi-Yonah, Diane M. Ring, and Yariv Brauner, U.S. International Taxation: Cases and Materials, Fifth Edition (Foundation Press 2022) (ISBN: 9781647082291). b) Bret Wells, International Taxation, Foundation Press (Concepts and Insights Series), Fifth Edition (2022) (ISBN: 9781636597744); c) CCH (Wolters Kluwer), "International Income Taxation--Code & Regulations, Selected Sections, 2024-2025 Edition," (ISBN: 9780808060253); d) Course Supplement (on Canvas)
