This is an introduction to U.S. taxation of U.S. and foreign persons engaged in international activities. Topics will include U.S. jurisdiction to tax, tax treaties, allocation of income, transfer pricing, foreign tax credits, etc. The class will 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 provide an overview of 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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