Tax Treaties and Other International Tax Topics

Section 1, Fall 22

Schedule Information

Enrollment: 15/30
Credits: 4
Days* Time Room Start Date End Date
  • TR
  • 0800-0950
  • WB105
08/30/2022 12/06/2022
*“R” means Thursday

Course Description

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.

Course Requirements

Exam Info:
Final Type (if any): None
Description: None

Written Work Product
Written Work Product: Students will be evaluated based on class participation, interim assignments as part of the simulation, their final client memorandum, and their in-class presentation. The final memo is due to be submitted via EXPO by noon (EST) on the last day of the finals period.

Other Work

Other Course Details
Prerequisites: Federal Income Tax recommended, but not required. Because the credits in this course count toward the JD Program Professional Skills requirement, JD candidates will be given enrollment priority for this class. Concurrencies: None
Mutually Exclusive With: None
Laptops Allowed: Yes
First Day Attendance Required: No
Course Resources: To be announced.
Course Notes: This course is a prerequisite for the International Tax Practicum (YR).

Graduation Requirements

*Satisfies Writing Requirement: No
**Credits For Prof. Skills Requirement: Yes
Satisfies Professional Ethics: No

*If “Yes,” then students are required to submit a substantial research paper in this course, which means students do not need to submit any form to SRO for this paper to meet their upper-level writing requirement. If “No,” then students must submit a “special request” e-form to SRO (available via LawWeb) no later than five weeks after the start of the term for a paper in this class to be counted toward the upper-level writing requirement.

**Yes indicates course credits count towards UVA Law’s Prof. Skills graduation requirement, not necessarily a skills requirements for any particular state bar.

Schedule No.
Law No.
Modified Type
Cross Listed: No
Cross-Listed Course Mnemonic:
Public Syllabus Link: None
Evaluation Portal Via LawWeb Opens: Monday, December 05, 12:01 AM
Evaluation Portal Via LawWeb Closes: Friday, December 09, 11:59 PM