Taxation of International Business Transactions gives students an overview of how international business taxation works. The course is beneficial to students interested in pursuing tax law, or more generally, corporate law. The course is one of the many tax-focused offerings for which Basic Federal Income Taxation is a prerequisite.
Students interested in working for a Fortune 500 company, or any company that conducts business overseas, will benefit from this course. Professor Grewal explained that “America’s largest companies have substantial operations overseas. This course will help students understand how those companies structure transactions.”
The course is heavily problem-based, and students will do a lot of close statutory analysis. Professor Grewal hopes that every student comes away knowing the “importance of understanding cross-border transactions for multinational and large corporations.”
Reece Clark, a 3L who took the course last spring, said that the course discussed the sourcing of income, as the source of income will determine which codes and regulations to apply. “I felt like I learned a lot about the framework for sourcing of income and what you need to consider or think about in that regard as a domestic entity operating abroad.”
Clark also emphasized that the course provides a forum for developing statutory interpretation skills, which is especially important in tax. “There’s a really interesting interplay between the different statutes and regulations,” Clark explained. “In an international tax situation, you not only have the Internal Revenue Code, but also treasury regulations and court opinions that involve comparative and international law.” Learning how courts deal with those interactions is a key component of the course.
Introduction to U.S. aspects of international taxation and international tax policy issues; how the United States taxes foreign persons on income they derive from U.S. sources; taxation of U.S. persons on their worldwide income; United States bilateral tax treaty network, under which many of the statutory rules regarding the taxation of foreigners are modified or supplanted; solving problems that illustrate the operation of the Code and regulations. Prerequisites: Basic Federal Income Taxation. Corequisites: Business Associations.
Thursday, Friday | 11:00 am – 12:30 pm