U.S. International Taxation II – Inbound
Course Number: LAW 7615 Credits: 2
- U.S. International Tax I(LAW 7614)
- Corporate Taxation I(LAW 7611)
The course concentrates on the U.S. taxation of foreign (non-U.S.) persons and foreign investments in the United States. The course covers the U.S. taxation of passive and business income of nonresident aliens, and foreign corporations and partnerships. A deeper review is made of the source rules, tax withholding on payments made to foreign persons, special rules like the branch profits tax and branch level interest tax, rules governing investments made by foreign governments and the entities that they control, the principles and application of U.S. tax treaties, special rules governing foreign investment in U.S. real estate and other business, cross-border financing transactions, and tax planning possibilities involved in the foregoing.