This course considers U.S. taxation of U.S. and foreign corporations engaged in international activities. Topics include U.S. jurisdiction to tax, tax treaties, allocation of income and expenses, transfer pricing, foreign tax credits, and anti-avoidance measures. Special attention will be paid to the new provisions introduced in the 2017 Tax Cuts and Jobs Act. The class also addresses some of the important procedural mechanisms by which international tax issues are resolved -- e.g., advance pricing agreements and Competent Authority negotiations. The goal of the class is to understand the relevant law, giving due respect to its complexity and the policies underlying it, and to identify and wrestle with the types of issues that most frequently arise.
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