U.S. Taxation of International Transactions

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This course analyzes the tax treatment, issues, planning techniques and underlying government policies involved in doing business internationally. The course incorporates concepts learned in all of the tax courses as they relate to the impact on cross-border outbound transactions (i.e., the taxation of US taxpayers doing business abroad). Topics include the source of income, transfer pricing, controlled foreign corporations (CFCs), Subpart F income, foreign tax credits, Global Intangible Low-Taxed Income (GILTI), Base Erosion and Anti-Abuse Tax (BEAT), and Foreign Derived Intangible Income (FDII). While this course focuses heavily on outbound transactions, some inbound rules (i.e., non-US taxpayers doing business in the United States) will be discussed. This course is an introductory course, so no prior knowledge of international taxation is required or expected. However, prior knowledge of U.S. federal taxation is necessary.