Intro to U.S. Taxation of Foreign Income

3 units

The course examines jurisdiction to tax, source of income, allocation of expenses, foreign tax credit mechanism, foreign tax credit limitation, transactions between related companies, tax favored transactions, organization/reorganization of entities involved in foreign jurisdictions and other related topics. [JD students interested in taking this course must receive special permission, and will receive a letter grade, which will not calculate into their JD GPA.]