375 - U.S. Taxation of International Transactions (3)

The course covers the application of federal income tax laws to U.S. citizens, residents, and corporations investing or doing business without the United States and nonresident aliens and foreign corporations investing or doing business within the United States. The course emphasizes fundamental issue of cross-border activities, including jurisdiction to impose tax, source of income provisions, foreign tax credit, income tax treaties, U.S. anti-deferral regime, transfer pricing, and nonrecognition transactions with foreign entities. (Practicum).