Courses 2013 - 2014
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.