Courses 2016 - 2017
LAW T 516
International Taxation II
The complement course to International Taxation I. This course covers the taxation of "outbound" foreign investment by U.S. taxpayers and will consider principles relating to the reach of U.S. taxation to U.S. persons on their "world-wide" income, the §911 exclusion for U.S. taxpayers living abroad, the foreign tax credit, including what constitutes a creditable payment and application of the direct and indirect credit rules, and taxation of controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs). Consideration will also be paid to mergers and demergers involving foreign subsidiaries, treatment of gain from sale of stock in foreign corporations (§482) and §367 requirements for outbound transfers.
Course Sections and Instructors
||Schedule - Days, Hour, Room)
||Sec SLN Type
A TBA Tax
B TBA JD
C TBA LLM
Room assignments are not posted until 30 days before the start of the quarter and are subject to change without notice.
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