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Courses 2008 - 2009

LAW T 516 International Taxation II

Credits: 3

Analysis of the taxation of "outbound" foreign investment by U.S. taxpayers. The course 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 (§1248), income allocation issues (transfer pricing) (§482); and §367 requirements for outbound transfers. Prerequisites: Introduction to Individual Income Taxation. Recommended T515 International Taxation I.

Winter, 3 Credit(s)

Course Sections and Instructors
Monica Gianni

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