Advanced International Corporate Tax Transactions

2 Credit Hours

This course addresses a variety of international corporate tax issues, including (i) section 367 consequences of asset transfers to foreign corporations, (ii) section 7874 consequences of inversions transactions and certain internal group restructurings, (iii) analysis of treatment of foreign losses, including the rules governing overall foreign losses, foreign branch losses and dual consolidated losses, and (iv) the interplay of certain Subchapter C and international tax provisions in the context of international tax planning for a U.S. multinational corporate group. Registration Requirements: Corporate Taxation and International Taxation are prerequisites for all students. The class is not a biddable class for JD and non-Tax LLM students. JD and non-Tax LLM students may only enroll in this class during the drop/add period with the permission of the instructor. Evaluation Methods: Final Examination.