Course Descriptions

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US Income Tax Treaties (LWTE537)

Instructor(s): Staff

2 credit(s), Letter Graded
Requirement(s): Writing
Concentration(s): International Law (JD), International Law (LLMUS), Taxation (LLMUS), LLM in Taxation (LLMT), LLM in International Law (LLMI), International Law (MSLS), Taxation (MSLS)

Under U.S. law, the provisions of the Internal Revenue Code must be applied "with due regard to any treaty obligation of the United States" that applies to a taxpayer.  Thus, this course examines the vast network of international agreements by which the United States and its treaty partners address matters ranging from alleviating double taxation on cross-border activities and investments, to exchanging tax information, allowing for consultations between and among tax authorities, and addressing actual and perceived tax abuses.  The course analyzes Bilateral income tax conventions (“tax treaties”), tax information exchange agreements (“TIEAs”), mutual assistance and cooperation matters (“MAP” and “Competent Authority”), certain compliance matters (e.g., FATCA and FATCA Agreements), and related subjects.  Included is a complete examination of the roles of Treasury and the IRS, the U.S. State Department, the OECD, and the U.N., foreign tax authorities, and the various web-based “resource centers” that are available for use by taxpayers and their tax authorities, alike. 

Note:

This is a seven week short course at the beginning of the semster.  The second seven week short course to follow this one is Transfer Pricing.