Curriculum Guide · Courses
Tax Treaties: A Practical Approach to Interpretation and Application
Professor M. Grace Fleeman
LL.M Seminar 897 (cross-listed) | 1 credit hours
This is a basic tax treaty course that will cover fundamental tax treaty concepts such as residency, permanent establishment, business profits, limitation on benefits, and relief from double taxation (including operation of the U.S. foreign tax credit rules). There will be an overview of treaty provisions that apply to investment income and income from the performance of services. In addition, students will learn about the interaction of tax treaties with U.S. internal tax law, the role of international organizations in interpreting tax treaties, procedures for resolving tax treaty disputes through the competent authority process, and strategies for researching tax treaties. This course is designed for students with little or no background in tax treaties. However, students will be expected to have a basic understanding of the U.S. tax rules that apply to foreign persons who receive income from the United States and U.S. persons who receive income from abroad. The course will be based primarily on the United States Model Income Tax Convention, together with selected case law and administrative authority. We will also look at selected provisions of the OECD Model Tax Convention. Students MAY receive credit for this course and Tax Treaties: Planning and Practice in the Private Sector (LAWG-846-11) taught by Professor De Vos.
Strongly Recommended: Prior or concurrent enrollment in a course in international taxation.
This course will meet on the following days during the Fall 2015 semester: 9/9, 9/16, 9/23, 9/30, 10/7, 10/14, and 10/21.