Course Description for International Taxation
Prerequisite: TAX 3011 with a "C" or better or TAX 6105 with a "C" or better
Description: This course involves a study of international taxation rules. Topics include a survey of the "source rules"; withholding tax issues; controlled foreign corporations; Subpart F and IRC n956 income; the foreign tax credit regime; utilization of tax treaties and executive agreements in tax planning; and transfer pricing rules. In addition, there will be a brief focus on foreign tax regimes as they affect the local activities of U.S. taxpayers.