ACC 639 Multijurisdictional Taxation (3)

Examines international, state, and local tax issues. Topics include U.S. International taxation of in- and out-bound transactions, sourcing of income and deductions and nexus.

Pre: 401

A minimum of at least C- or better is required

Subjects:

• Tax treaties
• Sourcing of income and deductions
• Taxation of Fixed Determinable and Periodic Income (FDAP)
• Taxation of Business Income
• Disposition of U.S. Real Estate
• Transfer pricing
• Foreign tax credits
• Nexus
• Types of state taxation (i.e., corporate, sales, excise, property)
• State Tax Base and Conformity
• Apportionment and Allocation
• Optional Topics: Controlled foreign corporations, expatriate taxation