U.S. International Taxation III – LLM

Prerequisites:

• U.S. International Tax I(LAW 7614)
• Corporate Taxation I(LAW 7611)

This is an advanced course in international taxation, and concentrates on the U.S. taxation of U.S. persons and businesses earning income outside of the United States. The course examines, in more depth, the rules governing U.S. persons’ ownership of foreign corporations (subpart F), the rules governing U.S. persons’ ability to claim a credit for taxes paid overseas (the foreign tax credit) and the rules applicable to transactions earned in foreign currency.  Significant amount of time will also be spent on rules applicable to outbound (from the United States) transfers of property cross-border, and cross-border mergers, acquisitions, spin-offs and dispositions.  The course will include consideration of different types of structuring transactions for both corporate and private U.S. investors. The course also includes consideration of the taxation of expatriates, calculations of earnings and profits, and Passive Foreign Investment Companies.