Law · Boston College
This course examines U.S. income tax laws and policies relating to the taxation of foreign income of U.S. persons and U.S. income of foreign persons. Emphasis will be on fundamental issues, such as jurisdiction to tax, source of income, U.S. taxation of foreign persons, relief from double taxation of income subject to taxing jurisdiction of two countries, U.S. taxation of foreign income earned by foreign entities owned by U.S. persons, transfer pricing in transactions between related parties, and income tax treaties. Reference will be made to how other countries address these international ta