Southwestern Law School Los Angeles, CA

International Income Taxation

616 | 2.0 credits


An introduction to the federal taxation of both "out-bound" and "in-bound" multinational transactions, the course focuses on the Internal Revenue Code's effort to reconcile often conflicting policies aimed at balancing and facilitating the needs of both U.S. nationals doing business int he U.S. In the "out-bound," the Code seeks to ensure that U.S. companies are not put at a competitive disadvantage with local organizations in carrying on a business overseas without making it more attractive tax-wise to carry on a business abroad than in the U.S. The statutory scheme for dealing with the problem of multiple taxation is addressed, along with the controlling Code, IRS court, and treaty procedures allowing the controlling deferral of tax on foreign income of U.S. companies, which is customarily not subjected to U.S. tax until "reported." Including is the intervention by such international organizations as the WTO, the OCED and NAFTA, as well as coverage of the "anti-abuse regulations," anti-bribery" and "anti-boycott" controls. Special attention is given to the potential impact of electronic commerce and "check-the-box regulations" (allowing choice of taxation in one form domestically and in another in the foreign country of operation and aimed at by-passing statutory limitations cast in the corporate model).


Business Associations


Survey of Federal Income Tax