ACCT 7369 - International Taxation

U.S. federal taxation of international transactions, e.g., “inbound” transactions (affecting nonresident aliens and foreign corporations) and “outbound” transactions (affecting U.S. persons, business, and investment activities outside the U.S.). Topics include jurisdiction, source of income rules, residency tests, transfer pricing, and tax treaties. In connection with “inbound” transactions, the course will address U.S. taxation of investments, business, U.S. real property investments; and branch profits tax. As to “outbound” transactions, the course will include the foreign tax credit; controlled foreign corporations, foreign currency issues; and other cross-border transactions. Open to MBA students and students in graduate accounting and taxation programs.

Prerequisites: ACCT 7355 with a B or greater or ACCT 4323 with a C or greater, and ACCT 4322 with a C or greater, or ACCT 7356 with a B or greater.
Concurrent: ACCT 7355 is permitted.