Curriculum Guide · Courses
U.S. Taxation of Domestic Persons With Activities Outside of the U.S.
LL.M Course 756 (cross-listed) | 2 credit hours
Concentrates on the U.S. taxation of U.S. persons and businesses earning income outside of the United States. The course examines, in depth, U.S. taxation of the international operations of U.S. multinational corporations. It covers Sections 367 and 1248, the Foreign Tax Credit provisions, and Subpart F, foreign currency considerations, and strategic tax planning. The course also includes consideration of the taxation of expatriates, calculations of earnings and profits, and Passive Foreign Investment Companies.
Prerequisite: Taxation I.
Students may not receive credit for both this course and the J.D. seminar, Congress and the Department of Justice Seminar: Conflict and Cooperation; or the J.D. seminar, International Tax Planning Seminar; or U.S. Taxation of International Transactions.
Formerly known as U.S. Taxation of International Income II