The global international taxation framework is currently in the midst of a historic upheaval aimed at making large corporations pay a fair share of tax. Understanding these developments and their context, including how they build upon the existing system, is important for students who aspire to practice in tax and corporate law, as well as those with an interest in how the international taxation system can be made more fair for developing countries.
The first part of this two-credit seminar will provide students an introduction to the fundamentals of the existing US international taxation system, addressing both the US activities of foreign persons and the foreign activities of US persons. Attention will also be devoted to key topics such as the potential for profit shifting through transfer pricing. The focus of this introduction will be on the policies underpinning the US rules.
The second part of the course will turn to recent global developments, including the 2013 Base Erosion and Profit Shifting (BEPS) project and its successors, Pillars One and Two of the ongoing work to revamp the international tax system. Pillar One proposes to reallocate a portion of large multinational corporations’ profits to the countries where their products are sold, while Pillar Two proposes a new global minimum tax.
Prerequisites: Students must have completed, or must be concurrently enrolled in, Basic Federal Income Taxation. This requirement may be waived for students with prior income tax work experience.