5387 International Tax - WELLS- 12381
Bret Wells (FACULTY)
Course Areas: Taxation
Time: 4:00p-5:30p TTH Location: 213 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: Read Avi-Yonah casebook (Introduction & Ch. 1 [pp. 1-33])
Read Isenberg & Wells Insights Book (Ch. 1 & Ch.2 [pp. 3-39])
Watch following Videos posted on Blackboard: (i) 2011 Senate Hearing (Clip #1 through Clip #3) & (ii) 2017 Senate Hearing (Clip #1 through Clip #4)
Final Exam Schedule: 04/30 9am-3pm
This course will have:
Satisfies Skills Course Requirement: No
Satisfies Senior Upper Level Writing Requirement: No
Experiential Course Type: No
Bar Course: No
DistanceEd ABA 306:
Pass-Fail Student Election:
Course Materials (11/7/2019 10:45:29 AM)
Course Materials: 3 Items ALL REQUIRED: (1) Reuven S. Avi-Yonah, Diane M. Ring, and Yariv Brauner, U.S. International Taxation: Cases and Materials, Fourth Edition (Foundation Press 2019) (ISBN: 9781683286509); (2) Joseph Isenbergh and Bret Wells, International Taxation, Foundation Press (Concepts and Insights Series), Fourth Edition (2019) (9781684673636); (3) CCH (Wolters Kluwer), "International Income Taxation: Codes and Regulations, Selected Sections, 2019-2020 Edition," ISBN: 9780808052166
The Course Supplement and additional materials will be made available by the Professor via his website during the semester.