LAW 509 - Foreign Taxation II

Unit(s): 2

Coverage of this class will include the rules surrounding US taxation of US owned and controlled foreign subsidiaries, including particular modifications to the US international tax rules under the Tax Cuts and Jobs Act of 2017, such as the taxation of Global Intangible Low-Tax Income, Foreign Derived Intangible Income, and certain topics pertaining to the foreign tax credit, an overview of the rules governing the pricing of transactions between controlled subsidiaries, select topics in international transactions (e.g., international M&A), general outbound tax planning, an introduction to the OECD’s Base Erosion and Profit Shifting Report, and, to the extent time permits, other relevant international tax issues.

Prerequisite: concurrent LAW 502 with a minimum grade of D or concurrent LAW 502 with a minimum grade of D or concurrent LAW 502 with a minimum grade of D
Restriction: College restricted to School of Law
School of Law