Course Details

International Taxation

The objective of this course is to familiarize students with the principles and underlying policies of the United States taxing system concerning: (1) income earned by United States citizens, resident aliens, and corporations from business and investment activities abroad and (2) income earned by nonresident alien individuals and foreign corporations from business and investment activities in the United States. Considers the basic international tax jurisdiction issues; source of income and allocation and apportionment of deduction rules; the taxation of foreign persons' United States trade or business income, including the concepts of "United States trade or business" and "effectively connected income"; the taxation of foreign persons' non-business income from United States sources, including the concept of "fixed or determinable annual or periodical gains, profits, and income" and the United States tax rules with respect to the sale of United States real property interests; an introduction to the foreign tax credit provisions; the foreign earned income exclusion in Section 911; the role of tax treaties; and an introduction to Subpart F and the other so-called "anti-deferral" mechanisms. Registration Requirements: Basic Federal Income Tax or enrollment in the Tax LLM program is a pre-requisite for this course. Non-TaxLLM students may not bid on this course, but may enroll during the add/drop period if there are open seats and they have met the pre-requisite. Method of Evaluation: Examination Class Materials: Full set of Federal Income Tax Code & Regulations (CCH or RIA) United States International Taxation, 3rd ed., Postlewaite, Sheffield, Baumeister & Tokic, (2015). LexisNexis International Taxation: Corporate and Individual, 9th ed., Postlewaite & Hoffer, (2014). Carolina Academic Press

Catalog Number: TAXLAW 670
Practice Areas: International Law Practice AreaTaxation Practice Area
Additional Course Information: LLM tax course open to JD students,  Tax Program Course


Course History

Fall 2017
Title: International Taxation
Faculty: Sheffield, Jeffrey T. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 54

Fall 2016
Title: International Taxation
Faculty: Sheffield, Jeffrey T. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 50

Fall 2015
Title: International Taxation
Faculty: Sheffield, Jeffrey T. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 60

Fall 2014
Title: International Taxation
Faculty: Postlewaite, Philip F. (courses | profile)
Sheffield, Jeffrey T. (courses | profile)
Section: 1     Credits: 2.0
Capacity: 59     Actual: 45