Study

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.

Special Notes:

*2 Credits

Enrollment Pre-/Co- Requisite Information

Federal Income Taxation or equivalent.

Spring 2023

Course Number	Course Credits	Evaluation Method	Instructor
360.01	Course Credits 2	Final Exam	Shu-yi Oei
Sakai site: https://sakai.duke.edu/portal/site/LAW-360-01-Sp22
Email list: LAW-360-01-Sp23@sakai.duke.edu