INTERNATIONAL TAXATION

The course will cover the basics of US taxation of international income earned by individuals and businesses, examine international tax norms, and compare different countries' tax rules. We will incorporate policy discussion and consideration of anti-abuse rules aimed at protecting global tax coffers. Topics include tax residence and "expatriation", source of income principles, the foreign tax credit, earnings stripping, transfer pricing, 2017 legislation regarding the taxation of foreign income, and the international tax treaty network.