TAX 6527 Multi-Jurisdictional Taxation
Master of Science in Taxation Program
M,W: 1:00pm-3:00pm, 4:30pm-5:45pm or by appointment
- U.S. Taxation of International Transactions, Schadelwald, & Misey 7th ed., CCH, 2009.
- International Income Taxation, Code and Regulations, Selected Sections, Pugh, Commerce Clearing House (latest available edition)
The objective of this course is to provide the student with a functional understanding of the concepts statutes, and judicial doctrines applicable to the multi-jurisdictional taxation (tax issues affected by where the taxpayer chooses to conduct business – outside of the U.S., international taxes and within the U.S., taxes imposed by the various states). The primary emphasis of the course will be on the concepts of international taxation.
METHOD OF INSTRUCTION
In addition to the assigned text readings additional revenue rulings, court decisions, and/or articles may also be assigned. Class discussion is the primary method of instruction in this seminar course. Accordingly, a refutable presumption exists that you will come to class prepared to discuss the day’s assignment.
|Midterm Examinations (2)
Two midterms and a final exam will be given during the semester. The final examination will only include material presented after the second midterm.
(Cases for each chapter are available on the course website or will be distributed in class)
||Introduction / Overview
||LABOR DAY HOLIDAY
||Foreign Persons Investing in the United States
||Foreign Persons Doing Business in the United States
||Foreign Tax Credit (pp. 73-105)
||Deemed Paid Foreign Tax Credit (pp. 105-140)
Cross-Border Transfers (pp. 543-555)
||Foreign Currency Translation and Transactions
||Planning for Foreign Operations
||Multi-State Taxation Issues
||FINAL EXAM 7:00pm-9:50pm
Last Updated: Friday, August 20, 2010.