|
 |
|
|
|
Diamond
Graduate School of Law LL.M. Program Syllabus for US International Taxation Fall
Semester only 16 weeks and an exam week October
1st week until last week January I. COURSE
DESCRIPTION
US-International Tax is a three-credit
LL.M. course whose emphasis is upon the federal taxation of (1) the U.S.-related
income of nonresident aliens and foreign corporations, and (2) the
foreign-related income of U.S. taxpayers. Topics include taxation of outbound
and inbound expatriates; the source of income and expense allocation rules; the
concepts of "US trade or business" and "effectively connected
income," and the effect of a tax treaty; the foreign tax credit; Subpart F,
PHC, PFIC and other anti-deferral mechanisms; FDAP income and withholding;
foreign investment in U.S. real estate and FIRPTA; and the next generation of
Foreign Sales Corporations tax preferences. Prerequisites or concurrently: either
Tax I or Principles of International Tax
II. PURPOSE US-International Tax is an LL.M. executive level course. Credit for this course may not be applied to the JD degree requirements. This course will be taught at the executive level and will employ case studies beyond IRC analysis. An LLM executive level course. This course will be taught at the executive level and will employ case studies as well as global case analysis. This course may with permission be counted toward both the concentrations of International and United States tax.
III.
COURSE PROCEDURE
This course will involve fourteen weekly modules that are delivered
through on-line instruction pursuant to current program specifications.
Each module will contain text material, study guide instruction, and
weekly interactive participation. Text
material may contain a combination of code sections, cases, and commentary
materials. Study guides will
contain commentary materials upon the text materials with imbedded exercises and
assignments to be completed either independently or within a group of two to
five persons. Assignments may be
submitted directly to the Instructor or submitted to the classroom. Each
module, selected students may be called upon to deliver answers in the Internet
based classroom to questions posed by the instructor.
Questions may be posed in case study form or in issue form.
Answers may be short (one page) form or long form (five page analysis). During
the semester, module based audio and videotape lecture construction will be
explored as well as the provision to students through streaming technology.
During the sixteen-week semester, the students will have two technology
skills and control weeks. The first
week of the course, the student will spend the time acquiring and testing the
necessary accessing components of the course, including: blackboard skills,
database access, proxy server access, material download, and other technical
issues. Also, students will
introduce themselves and identify with each other (camaraderie and network
building). During the third week,
students will be given another breather week to check the quality of their
acquired technology technical skills and offsite database access in order to
identify any problem areas that require immediate correcting.
During the semester, each student will receive at least two detailed
feedback sessions from the Instructor through the detailed marking of
his/her/group study guide assignments and/or class participation.
Separately, the Instructor is available for office hour private
counseling through email, telephone, and by residential office appointment. Other
assignments may receive feedback and will receive a grade, recorded in the
online grade book that students may assess their performance. IV. ATTENDANCE AND
PARTICIPATION
This
online course requires attendance which is measured by (1) the modular-weekly
interactive participation opportunities in the classroom, (2) mandatory weekly
participation through being called upon to address the class for certain modules
as well as (3) modular study guide assignments.
Missing mandatory weekly participation assignments is the equivalent of
being not prepared in class and will result in a zero for that assignment.
Not turning in study guide assignments will result in a zero for that
assignment. V. EVALUATION OF STUDENT
PERFORMANCE
Grades will be determined through a combination of factors, as follows: final
exam 25%; final
ten page paper 25% weekly
study guide assignments 25% weekly
participation 25% VI. REQUIRED TEXTS
Electronic
texts edited and authored by the Instructor, supplemented by reference
materials. Reference materials will
include source materials and secondary materials. VII.
REFERENCE MATERIAL
Reference material will be drawn and
accessed from Internet enabled databases. These
databases are already part of the database collection provided to all students
in the LLM program.
BNA international tax materials
CCH international tax materials Tax Analysts
Butterworths Checkpoint
International Tax Materials (Thomson Taxs amalgamation of RIA, WG&L, and
Gee)
Mathew Bender international tax materials
Oceana Tax Treaties database
Westlaw tax databases - international
Lexis tax databases - international
Quicklaw tax databases
Foreign Law Publishers
tax journal and law review Internet enabled sites VIII.
WEEKLY SYLLABUS
Module 1: US
international tax policy and treaty policy
Module 2: expatriates and
expatriation outbound
Module 3: expatriates
inbound and beginning of source rules
Module 4: source rules:
deductions and FDAP income
Module 5: trade or
business, ECI, permanent establishment
Module 6: withholding
issues and treaty relief issues
Module 7: inbound real
estate investment and FIRPTA
Module 8: CFC,
attribution issues
Module 9: PFHC, PFIC
Module 10: Other foreign reporting and
other anti-deferral
Module 11: Foreign tax credit
Module 12: FSCs and what is to come,
foreign territory tax preferences
Module 13: transfer pricing
Module 14: current issues and
presentation of course paper |