US International Tax Law

This course will be co-taught with Tijana Dvornic in Spring 2024.

The course is an introduction to the Internal Revenue Code and U.S. Income Tax Treaty provisions that govern the taxation of the income of U.S. resident corporations and individuals earned outside the United States and the income of Non-U.S. residents earned from within the United States. The course will principally explore relevant statutory and treaty texts and, to a
more limited extent, IRS regulations, caselaw and other guidance. Articles and other secondary sources will be provided to aid in understanding these rules. The primary emphasis of the course will be on the tax treatment of various transactions undertaken by business entities. Classes will include lectures and problem sets that focus on the tax aspects of specific types of cross-border commercial transactions (such as inventory sale agreements, intellectual property license and services agreements), joint venture arrangements and cross-border mergers and acquisitions. Students will also learn how tax considerations inform the organizational structures of U.S. and non-U.S. multinational enterprises. The course is intended to provide a useful learning experience for students interested in international business organizations and transactions as well as for students interested in broadening their understanding of tax law.