Tax Treaties and Other International Tax Topics

This course examines the fundamental issues that countries confront when they impose income taxes on cross-border transactions involving the movement of goods, services, capital, businesses, and individuals. This course is different from International Tax, and it can be taken before, after, or concurrently with that course. International Tax focuses on the U.S. Internal Revenue Code and examines how the United States taxes (1) nonresidents’ economic activities within the United States and (2) U.S. residents’ economic activities abroad. By contrast, Tax Treaties and Topics in International Tax does not focus primarily on the Code or U.S. law. Instead, it covers issues that are important for understanding international tax, but that generally are not covered (or are only briefly covered) in International Tax, including tax treaties, exchange of information, and transfer pricing (transactions that occur between divisions or subsidiaries of a single multinational enterprise). We will focus on multilateral responses to problems, including determining which state(s) should tax cross-border income, tax enforcement against nonresident taxpayers, prevention of corporate tax avoidance and individual tax evasion, and managing tax competition. Reading materials will include tax treaties, OECD materials, journal articles, and may include cases from any jurisdiction. This course satisfies the skills requirement. As such, a major part of this course will be a simulation in which students will write client memoranda and give a presentation on an international tax topic to be chosen in consultation with Prof. Mason.