Details

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 '911; the role of tax treaties; and an introduction to Subpart F and the other so-called "anti-deferral" mechanisms. Method of Evaluation: Examination Method of Instruction: Problem Method Basic Federal Income Tax is a pre-requisite for JD candidates. JD and non-Tax LLM students may only enroll in this class during the drop/add period. The class is not a biddable class for JD and non-Tax LLM students.