Details

This course provides an in-depth examination of tax treaties and their role as the principal source of international law governing the tax treatment of cross-border transactions. After a review of some of the basic principles of international tax law, the course will focus on a detailed analysis of the OECD and United States Model Income Tax Treaties. The course also examines the policy objectives and processes of the United States and other countries in negotiating and concluding tax treaties. The interpretation of tax treaties and the legal status of tax treaties in the United States and other countries are also compared. Pre-requisite: International Tax and not open to second year JD students who are not enrolled in the Joint Degree Program without the permission of the instructor. Basic Federal Income Tax is a pre-requisite for JD candidates.