About
This course introduces the fundamental U.S. income tax issues arising when (1) U.S. persons or entities earn income outside of the U.S. or (2) foreign persons or entities earn income inside the U.S. Specific topics may include the rules for classifying income as U.S. or foreign-source income, transfer pricing, income deferral and controlled foreign corporations, double taxation and the foreign tax credit, foreign currency transactions, and the role of tax treaties. It will highlight significant differences between the U.S. approach to cross-border transactions and those adopted by other taxing authorities.