ACC 639 Multijurisdictional Taxation (2)

Examines international, state, and local tax issues. Topics include U.S. International taxation of in- and out-bound transactions, sourcing of income and deductions and nexus. Pre: 401 with C- or better.

Subjects:

  • Tax treaties
  • Sourcing of income and deductions
  • Taxation of Fixed Determinable and Periodic Income (FDAP)
  • Taxation of Business Income
  • Disposition of U.S. Real Estate
  • Transfer pricing
  • Foreign tax credits
  • Nexus
  • Types of state taxation (i.e., corporate, sales, excise, property)
  • State Tax Base and Conformity
  • Apportionment and Allocation
  • Optional Topics: Controlled foreign corporations, expatriate taxation