The purpose of this courses it to offer an introduction to United States international taxation. The topics to be addressed include the following:

 

1. United States international tax policy and jurisdiction to tax – residence of individuals and corporations, entity classification and the “check-the-box” rules;

2. The source of income and allocation of deductions;

3. The taxation of non-business income such as dividends, interest, royalties, capital gains; special exemptions and FIRPTA;

4. The taxation of business income including the concepts of trade or business/ permanent establishment;“ effectively connected income”/ “attributable to” concepts; the branch profits tax and branch level interest tax;

5. The problem of deferral including the basics of subpart F, the definition of controlled foreign corporations, current inclusions and the previously taxed earnings concept; foreign personal holding company income and foreign base company sales and  services income, section 960 credits, major exceptions in subpart F, and section 1248;

6. The foreign tax credit, including eligibility for credit and creditable taxes; section 904; the general limitation and baskets; the indirect, deemed paid foreign tax credit of section 902;

7. Introduction to international reorganizations including section 367 and gain recognition and outbound transfers of intangibles; and 

8. United States tax treaties and their role in international tax practice.