360 International Taxation

This course covers the basic rules governing the U.S. income taxation of international business and investment transactions. After a brief explanation of basic American income tax concepts, the principal rules of taxation relating to income of American taxpayers that is earned abroad, and the income of foreign taxpayers that is earned in the U.S., will be described and discussed. The course will then focus on how the United States’ rules interact with taxation systems in other countries, exploring the concepts of source of income and residence of the taxpayer, and their role in the tax rules relating to international trade. The course will also include consideration of the role of bilateral tax treaties as a means of promoting crossborder investments and international trade through the avoidance of international double taxation. The OECD model treaty will be examined as an illustration of the interaction between double tax treaties and domestic regulations. The course will also describe and discuss the role of transfer pricing in tax avoidance efforts by business taxpayers, especially U.S. multinational corporations.  Finally, the course will explore recent developments in the international effort to reduce tax-base erosion and income shifting among taxing jurisdictions.

Enrollment Pre-/Co- Requisite Information

Federal Income Taxation or equivalent.

Course Areas of Practice
Evaluation Methods
  • Final Exam
Degree Requirements
Course Type
  • Lecture
Learning Outcomes
  • Knowledge and understanding of substantive and procedural law

Spring 2022

2022
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 2
  • Final Exam
Richard L. Schmalbeck W 4:00-5:50 PM 3171

This course covers the basic rules governing the U.S. income taxation of international business and investment transactions. After a brief explanation of basic American income tax concepts, the principal rules of taxation relating to income of American taxpayers that is earned abroad, and the income of foreign taxpayers that is earned in the U.S., will be described and discussed. The course will then focus on how the United States’ rules interact with taxation systems in other countries, exploring the concepts of source of income and residence of the taxpayer, and their role in the tax rules relating to international trade. The course will also include consideration of the role of bilateral tax treaties as a means of promoting crossborder investments and international trade through the avoidance of international double taxation. The OECD model treaty will be examined as an illustration of the interaction between double tax treaties and domestic regulations. The course will also describe and discuss the role of transfer pricing in tax avoidance efforts by business taxpayers, especially U.S. multinational corporations.  Finally, the course will explore recent developments in the international effort to reduce tax-base erosion and income shifting among taxing jurisdictions.

Pre/Co-requisites

Federal Income Taxation or equivalent.

Spring 2021

2021
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3
  • Final Exam
Peter A. Barnes M/W 5:10 PM-6:35 PM

The course explores both the existing tax rules and the widespread policy concerns under discussion in the US and globally about current international tax law.

Pre/Co-requisites

Federal Income Taxation or equivalent.

Spring 2020

2020
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3
  • Final Exam
Peter A. Barnes MW 5:10-6:35 PM 3043

The course explores both the existing tax rules and the widespread policy concerns under discussion in the US and globally about current international tax law.

Pre/Co-requisites
Federal Income Taxation

Spring 2019

2019
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3
  • Final Exam
Peter A. Barnes M/W 4:50-6:15 PM 3043

The course explores both the existing tax rules and the widespread policy concerns under discussion in the US and globally about current international tax law.

Pre/Co-requisites
Federal Income Taxation

Spring 2018

2018
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3
  • Final Exam
Peter A. Barnes MW 4:50-6:15 PM 4172

The course explores both the existing tax rules and the widespread policy concerns under discussion in the US and globally about current international tax law.

Pre/Co-requisites
Federal Income Taxation

Spring 2017

2017
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3
  • Scheduled in-class examination
Peter A. Barnes MW 4:50-6:10 PM 4172

The course explores both the existing tax rules and the widespread policy concerns under discussion in the US and globally about current international tax law.

Pre/Co-requisites
Federal Income Taxation

Spring 2016

2016
Course Number Course Credits Evaluation Method Instructor Meeting Days/Times Room

360.01 3 Peter A. Barnes MW 4:50-6:10 PM 3171

This course examines the United States federal income taxation of (1) foreign persons and corporations on their US-source income (taxation of "inbound" transactions), and (2) US residents, citizens, and corporations on their foreign-source income (taxation of "outbound" transactions).

Pre/Co-requisites

Law 255 Federal Tax
Law 326 Corporate Tax is highly recommended but not required (and may be taken concurrently).

*Please note that this information is for planning purposes only, and should not be relied upon for the schedule for a given semester. Faculty leaves and sabbaticals, as well as other curriculum considerations, will sometimes affect when a course may be offered.