Course Details

International Tax of Partnerships

The use of partnerships and other tax-transparent entities has become a critically important component of international tax planning. This course explores the complex and oftentimes uncertain interaction between the international provisions of the Internal Revenue Code and the partnership provisions of subchapter K. There is no unifying theory or approach, only an incomplete patchwork of provisions that attempt to integrate and coordinate these two areas of tax law. Topics covered will include entity classifications; cross-border partnership formations; inbound and outbound operations through partnership structures; special allocations of foreign taxes and indirect foreign tax credits; PFICs, CFC partners and subpart F partnership blockers; and international partnership dispositions and alternative exit issues. Registration Requirements: Partnership Taxation and International Taxation Evaluation Method: Final Examination

Catalog Number: TAXLAW 669


Course History

Spring 2017
Title: International Tax of Partnerships
Faculty: Weiss, Mitchell B. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 16

Spring 2016
Title: International Tax of Partnerships
Faculty: Postlewaite, Philip F. (courses | profile)
Weiss, Mitchell B. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 25     Actual: 12

Spring 2015
Title: International Tax of Partnerships
Faculty: Postlewaite, Philip F. (courses | profile)
Weiss, Mitchell B. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 25     Actual: 12