International Taxation

3 units

Pre/co-requisite: Federal Income Tax (although Prof. Rosenzweig will entertain requests for a waiver of this requirement from students who believe that special circumstances warrant an exception). This course provides an introduction to the US system of taxation of income earned outside the United States by US citizens and residents (including domestic corporations) and income earned within the United States by nonresident individuals and foreign corporations. The course will cover issues including jurisdiction to tax, sourcing of income and deductions, net income tax on operating a US trade or business, gross income tax on US non-business income, the foreign income exemption for US corporations, and double tax relief methods for US individuals. The course grade will be based predominately on a three-hour in-school final examination, which will consist primarily of short essay questions. The final will be open book.