This course examines the United States federal income taxation of international operations and transactions, including international joint ventures and M&A transactions. Traditional issues such as income source, foreign tax credits, Subpart F, and international transfer pricing rules will be addressed. Congress recently enacted fundamental reform of US international tax rules; important new provisions in this area, including the "GILTI" rules, will also be covered. Elements used in grading: Final Exam.
2 units · Law Honors/Pass/Restrd Cr/Fail
This course examines the United States federal income taxation of international operations and transactions, including international joint ventures and M&A transactions. Traditional issues such as income source, foreign tax credits, Subpart F, and international transfer pricing rules will be addressed. Congress recently enacted fundamental reform of US international tax rules; important new provisions in this area, including the "GILTI" rules, will also be covered. Elements used in grading: Final Exam.