Walsh

TAX 550 INTERNATIONAL TAXATION

The application of the Internal Revenue Code to domestic corporations doing business in foreign countries either through subsidiaries or as branch operations. Topics include planning for expansion into foreign countries and developing countries; factors to consider in deciding whether to create a branch or a subsidiary in a foreign country; the foreign tax credit; dividend requirements; Subpart F and current international tax problems and planning. Inter-company pricing will be considered in detail. Also covered are tax treaties; FSCs, foreign currency; and the U.S. tax treatment of foreign persons and foreign businesses engaged in U.S. activity.

Credits

3

Prerequisite

TAX 500, TAX 510, TAX 531 and TAX 599

Distribution

TAXATION