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