Subjects 2009
International Aspects of US Income Tax (formerly United States Corporate and International Tax) 730746
- Credited Courses: Graduate Diploma in International Law 323; Graduate Diploma in International Law 323; Graduate Diploma in International Tax 191; Graduate Diploma in International Tax 191; Graduate Diploma in Legal Studies L08; Graduate Diploma in Tax 187; Graduate Diploma in Tax 187; Graduate Diploma in Transnational Law 333; Master of Commercial Law 504; Master of Commercial Law 504; Master of International Tax 192; Master of International Tax 192; Master of Laws (LLM) 502; Master of Laws (LLM) 502; Master of Public and International Law 511; Master of Public and International Law 511; Master of Tax 742; Master of Tax 742
Objectives
International taxation is a complex and very important subject. Its reach is extensive and its relevance to cross-border business pervasive. The United States has been a leader in this field for many years, and its laws and principles are important both in themselves and for other countries.
This subject provides a detailed understanding of US 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
- An introduction to the rules regarding controlled foreign corporations and foreign investment companies.
Syllabus
The US 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). This subject will examine US international income tax rules, with particular reference to aspects that are relevant to Australians investing in the US and to US investment offshore in Australia.
Principal topics will include the US tax rules on:
- US international tax
- Cross-border portfolio investment
- US tax treaties
- Transfer pricing
- Foreign tax credit
- CFC rules.
