MTAX 6430 - International Taxation

International taxation focuses on the U.S. taxation of cross-border transactions. A review of the Internal Revenue Code’s basic international tax rules is covered, including residency rules, sourcing of income and expenses, taxation of in-bound transactions (FDAP and “effectively connected income” rules), overview of U.S. model tax treaty provisions, anti-deferral regimes, and foreign tax credits. Students are often required to study the tax regimes of another country to compare and contrast foreign tax laws to U.S. laws. A brief review of interest-charge domestic international sales corporations is often covered. Prereq: Grade of C (2.0) or higher in ACCT 6140 or ACCT 4410 or at least 6 credit hours of MTAX courses. Restriction: Restricted to graduate majors and NDGR majors with a sub-plan of NBA or CPA within the Business School. Max hours: 3 Credits. Semester Hours: 3 to 3