Curriculum Guide · Courses

Professor Jonathan Talisman

LL.M Seminar 2038 (cross-listed) | 2 credit hours

This colloquium will offer students an opportunity to examine a current tax policy issue in depth and at an advanced level, with discussions led by policymakers, public finance experts, economists and tax scholars. The primary focus of the course will be an exploration of international tax reform, surrounding the current policy debate over whether the United States should adopt a territorial tax system or retain a worldwide tax system. The course will discuss various international reform proposals at a detailed level and examine the economic, tax policy and political considerations underlying the decisions that have been made in each proposal. The course will begin with a brief overview of our current international tax system and a comparison to other countries’ systems. It will examine the policy reasons why the United Kingdom and Japan have recently adopted a territorial system. It will explore the economic and policy literature surrounding the issues of economic welfare, competitiveness and outsourcing. Through a review of current proposals, the course will address in detail design issues and policy decisions, including overall objectives, treatment of foreign source income, retention/expansion of subpart F, IP migration, transfer pricing issues, and transition issues. Reading materials generally will be supplied and will include economic and tax policy papers, legislative proposals, and technical explanations. The course is intended to be highly interactive with students discussing design and policy issues with several of the leading experts in the field. The grade for this course will be based primarily on reaction papers that students submit addressing the topics discussed by the guest speakers. Useful class participation will be taken into account as a plus in determining the final grade. There will be no final exam.

Recommended: Taxation I