Topics in International Tax
This course examines the fundamental issues that countries confront as they attempt to impose income taxes on cross-boarder 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 nonresidents' economic activities within the United States and U.S. residents' economic activities abroad. By contrast, 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 tax of transactions that occur between divisions or subsidiaries of a single multinational enterprise (transfer pricing). We will focus on multilateral responses to problems including determining which state(s) should tax cross-boarder 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.
*Yes means professor requires everyone in the course to submit a substantial research paper (which is the requirement standard in Academic Policies), so no paperwork required to be submitted to SRO. No means student must timely submit paperwork to SRO if intending to use a paper in this course to satisfy the 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.