TAX 6527

TAX 6527 Multi-Jurisdictional Taxation

(Fall 2010)

Master of Science in Taxation Program

Syllabus

OFFICE HOURS:

M,W: 1:00pm-3:00pm, 4:30pm-5:45pm or by appointment

TEXTS:

  1. U.S. Taxation of International Transactions, Schadelwald, & Misey 7th ed., CCH, 2009.
  2. International Income Taxation, Code and Regulations, Selected Sections, Pugh, Commerce Clearing House (latest available edition)

COURSE DESCRIPTION:

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.

GRADES:

  Percent Points
Midterm Examinations (2) 70% 280
Final Examination   30% 120
Total 100% 400

EXAMINATIONS:

Two midterms and a final exam will be given during the semester. The final examination will only include material presented after the second midterm.

Assignments:

(Cases for each chapter are available on the course website or will be distributed in class)

Date Topic Chapter
August 23 Introduction / Overview 1
August 30 Tax Jurisdiction 2
September 6 LABOR DAY HOLIDAY  
September 13 Foreign Persons Investing in the United States 9
September 20 Foreign Persons Doing Business in the United States 10
September 27 Source-of-Income Rules 3
October 4 1st MIDTERM  
October 11 Foreign Tax Credit (pp. 73-105) 4
October 18 Deemed Paid Foreign Tax Credit (pp. 105-140) 4
October 25 Anti-Deferral Provisions
Cross-Border Transfers (pp. 543-555)
5
14
October 23 2nd MIDTERM  
November 1 Foreign Currency Translation and Transactions 6
November 8 Tax Treaties 13
November 15 Planning for Foreign Operations 8
November 22 Transfer Pricing 12
November 29 Multi-State Taxation Issues TBD
December 6 Review  
December 13 FINAL EXAM 7:00pm-9:50pm  

Last Updated: Friday, August 20, 2010.