International Taxation

The course covers the United States taxation of international transactions, including both "inbound" and "outbound" transactions. Topics will include U.S. tax jurisdiction, the international tax treaty network, classification of individuals and entities as U.S. or foreign, the source of income principles, the taxation of U.S.-source business and investment income earned by foreign persons, cross-border property transfers and transfer pricing, the foreign tax credit, controlled foreign corporations, passive foreign investment companies and foreign currency transactions.