Curriculum Guide · Courses

Professors Lara Banjanin and Jesse Eggert

LL.M Course 746 | 1 credit hours

Tax treaties provide rules for allocating taxing rights between jurisdictions, and provide certainty to businesses and individuals with activities in multiple countries regarding their potential tax liability. This course explores the basic principles governing the interpretation and application of tax treaties, using the U.S. Model Tax Convention as a starting point for examining specific provisions found in current U.S. tax treaties.

The course will cover fundamental tax treaty concepts such as scope and residency requirements (with particular attention to anti-treaty shopping rules unique to U.S. tax treaties), permanent establishment, attribution of profits, transfer pricing, allocation of taxing rights on investment income, relief from double taxation, and non-discrimination. Students will also learn about the interaction of tax treaties with U.S. domestic tax rules.

Prerequisite: Taxation I and one course in international taxation.

Students may not receive credit for both this course and the LL.M. Seminar, Tax Treaties: A Practical Approach to Interpretation and Application.

JD students who have not taken Taxation I and Taxation II should consult Ellis Duncan (ged5@law.georgetown.edu) before enrolling in this course.