This course offers a deep dive into the complex and evolving world of international taxation, focusing primarily on the U.S. international tax system while integrating global principles and comparative perspectives. It covers the taxation of inbound and outbound investments, income sourcing, transfer pricing, foreign tax credits, anti-deferral rules (Subpart F, GILTI), treaty interpretation, base erosion rules, and OECD efforts to combat tax avoidance.
Students will explore legal and policy issues arising from globalization, digital commerce, multinational operations, and the international effort to create fair and coherent tax frameworks in an era of corporate mobility and aggressive tax planning. This course combines statutory interpretation, treaty analysis, tax planning strategies, and policy critique to provide a full-spectrum understanding of how nations—including the U.S.—tax cross-border activity.
Course Objectives:
By the end of this course, students will be able to:
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Understand the structure and principles of U.S. international taxation, including rules governing foreign income and foreign persons.
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Determine how income is sourced and how sourcing affects taxability.
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Apply rules for determining the residence of individuals and entities for tax purposes.
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Analyze outbound and inbound tax regimes, including anti-deferral provisions.
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Evaluate the U.S. foreign tax credit system and its limitations.
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Interpret tax treaties using the Vienna Convention and OECD Model.
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Understand transfer pricing principles under IRC §482 and OECD Guidelines.
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Assess policy challenges posed by tax havens, base erosion, and global digital economy.
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Navigate global efforts to implement BEPS (Base Erosion and Profit Shifting) reforms and Pillar 1 and 2 initiatives.
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Apply international tax planning and compliance frameworks to real-world multinational structures.
