U.S. Taxation of International Transactions

This course examines international tax issues and planning strategies. This course combines concepts from all tax courses in order to address the effect on cross-border transactions (i.e. the taxation of US taxpayers doing international business). The course covers topics such as the source of income and transfer pricing. CFCs are controlled foreign corporations. Subpart F income is also covered. Global Intangible Low Tax Income (GILTI), Base erosion and Anti-Abuse tax (BEAT), Foreign Derived Itangible Income (FDII) are some other topics. This course will focus heavily on outbound transactions but also discuss inbound rules (e.g., non-US taxpayers doing businesses in the United States). It is an introductory course and therefore no prior knowledge is necessary or expected. However, it is recommended that you have some knowledge about U.S. taxation.