MTAX 6432 - Outbound International Taxation

Outbound international taxation addresses U.S. tax issues when a U.S. person (e.g., U.S. individual, partnership, or corporation) is investing or doing business abroad. For U.S. individuals working abroad, this course covers the foreign income exclusion and the housing exclusion. The foreign tax credit protects both the U.S. individual or business from double taxation, but only if correctly structured when dealing with closely held U.S. businesses. From a business perspective, the deferral aspects of a foreign corporation are covered, as well as the anti-deferral regimes of (1) a controlled foreign corporation with subpart F income and (2) the passive foreign income company (PFIC). Planning issues such as creating foreign source income, corporate reorganizations under IRC § 367 are also discussed. 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 business 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