International Tax

International taxation profoundly shapes modern business activities. Large companies, such as Apple, Google and Microsoft, structure their activities in sophisticated ways to minimize their tax liabilities. The importance of international taxation is bound to increase with the predicted rise in global economic activity and integration. Consequently, most tax lawyers practice today, at least to some extent, in the international arena. This course introduces students to U.S. income tax laws, treaties, and policies relating to international transactions. The course emphasizes fundamental issues and legal concepts as they relate to the taxation of foreign income of U.S. persons, and U.S. income of foreign persons. Income Tax is a prerequisite, unless a student has prior tax experience. There are no other prerequisites, and a review of the relevant material from Income Tax will be done in the beginning of the course.