US International Tax Law

The course is an introduction to the Internal Revenue Code and
U.S. Income Tax Treaty provisions that govern the taxation of
the income of U.S. resident corporations and individuals earned
outside the United States and the income of Non-U.S. residents
earned from within the United States. The course will
principally explore relevant statutory and treaty texts and, to a
more limited extent, IRS regulations, caselaw and other
guidance. Articles and other secondary sources will be provided
to aid in understanding these rules.
The primary emphasis of the course will be on the tax treatment
of various transactions undertaken by business entities. Classes
will include lectures and problem sets that focus on the tax
aspects of specific types of cross-border commercial
transactions (such as inventory sale agreements, intellectual
property license and services agreements), joint venture
arrangements and cross-border mergers and acquisitions.
Students will also learn how tax considerations inform the
organizational structures of U.S. and non-U.S. multinational
enterprises. The course is intended to provide a useful learning
experience for students interested in international business
organizations and transactions as well as for students interested
in broadening their understanding of tax law.