This upper-level, substantive course examines the issue of U.S. tax residence and the impact of this status for individuals who are U.S. citizens, U.S. permanent residents and nonresident aliens, including the problems of potential double taxation by two or more countries, relevant source rules, and other issues related to in-bound capital and individuals and solutions offered by tax treaties. These subjects are important in the practice of immigration law, family law, and estate planning, as well as for tax and general business law students.
This course also examines the U.S. tax laws applicable to multinational businesses, foreign currencies, and international business transactions of many kinds. It introduces students to source rules, the foreign tax credits system, and controlled foreign corporations, export trade corporations, and domestic international sales corporations. The impact of bilateral tax treaties between the United States and its trading partners and the impact of other tax treaties such as the European Union tax harmonization efforts will be discussed.
Open to Tax LL.M. students only.
Recommended for the following Professional Pathways: Corporate Transactions and Governance; Financial Services and Compliance; International Business; Tax; Trusts and Estates
Prerequisite or Co-requisite: Federal Income Tax: Individual and Federal Income Tax: Corporate