Subjects 2008
United States Corporate and International Tax 730746
- Credited Courses: Graduate Diploma in International Law 323; Graduate Diploma in International Tax 191; Graduate Diploma in Legal Studies L08; Graduate Diploma in Tax 187; Graduate Diploma in Transnational Law 333; Graduate Diploma in Transnational Law 333; Master of Commercial Law 504; Master of International Tax 192; Master of Laws (LLM) 502; Master of Laws (LLM) 502; Master of Laws by Coursework (LLM) 502; Master of Public and International Law 511; Master of Tax 742
Objectives
A candidate who has successfully completed the subject should have:
- A general understanding of the basic principles of United States Federal income tax. The subject will highlight differences from, and similarities to, Australian income tax
- An understanding of United States taxation of the corporation as a business entity, including rules for definition of the corporate tax base, corporate-shareholder transactions, mergers and acquisitions, and an introduction to the consolidated group rules
- An understanding of United States international tax rules for inbound and outbound investment, including taxation of portfolio and business cross-border investment; transfer pricing; thin capitalisation; cross-border mergers; the foreign tax credit; and an introduction to the rules regarding controlled foreign corporations and foreign investment companies.
Syllabus
The United States Federal income tax is contained in the Internal Revenue Code (Title 26 of the United States Code), together with regulations, cases, rulings and other documents produced by Treasury and the Internal Revenue Service (IRS). The subject will examine United States income tax, with particular reference to aspects that are relevant to Australians investing in the United States and to United States investment offshore in Australia.
Principal topics will include:
- Basic principles of the United States Federal income tax
- United States corporate tax
- United States international tax.
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| Yariv Brauner |