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Fall 2013 - International Tax

Peroni, Robert J

Course ID: 274R  Unique # 29230  Credit Hours: 2
Meeting DaysTimesLocation
   Tuesday 3:45 pm - 5:35 pm TNH 2.124
Exam Type   Date   Time      Name Range   Room  
  Final Wednesday, December 18    1:30 pm          A-Z
Registration Information
This course is restricted to upper division students only.

This course examines the U.S.  income tax laws and policies relating to the taxation of foreign persons' investment or business activities in the United States ("inbound") and U.S.  persons' direct or indirect investment or business activities in other countries ("outbound").  After an introductory overview, it addresses the taxation of inbound activities, covering, principally, the topics of residence, the source of income and deductions, the taxation of investment activities (including portfolio investment and real estate investment), and the taxation of U.S.  business activities of foreign persons.  The subsequent consideration of the taxation of outbound activities concentrates primarily on the foreign tax credit system and the various anti-deferral regimes (principally Subpart F).  Throughout, the course examines the relevant U.S.  domestic law and treaty provisions.  The grade for the course will be based on a final, open book examination.  Two units.

Prerequisite:  Federal Income Taxation

Taxation of International Transactions - Gustafson, Peroni & Pugh
  West Group, edition: 4th
International Income TaxationCode and RegulationsSelected Sections - Robert J. Peroni ed.
  CCH, edition: 2013-2014 ED