Tax Planning and Reporting Issues for Cross-Border Transactions
Course Number: LAW 7931 Credits: 3
- U.S. International Tax I(LAW 7614)
- Corporate Taxation II(LAW 7613)
The course will draw from discussions in other international tax courses to focus on and survey the many structuring and reporting issues that arise in the context of privately-held businesses and other investments made and held in a cross-border international context (e.g., choice of entities and holding company structure in multiple jurisdictions, governance and legal restraints, use of tax treaties, earnings and income distributions. Much cross-border investment is now in the form of portfolio investment rather than the traditional direct investment, and much of both is pursued by families and high-wealth individuals. The course will also consider current stresses in the applicable rules generated by developments in the OECD Base Erosion and Profits Shifting projects, and other U.S. and foreign government processes to reform them. Finally, the course will consider current reporting and compliance issues that taxpayers face when building and operating the resulting structures, and the significant penalties they face for noncompliance with these requirements.