MTAX 6430

International Taxation

International taxation focuses on the U.S. taxation of cross-border transactions. A review of the Internal Revenue Codes basic international tax rules is covered, including residency rules, sourcing of income and expenses, taxation of in-bound transactions (FDAP and effectively connected income rules), overview of U.S. model tax treaty provisions, anti-deferral regimes, and foreign tax credits. Students are often required to study the tax regimes of another country to compare and contrast foreign tax laws to U.S. laws. A brief review of interest-charge domestic international sales corporations is often covered. Restriction: Restricted to graduate majors and NDGR majors with a sub-plan of NBA or CPA within the Business School.

Units: 3.0

Hours: 3 to 3