Very excited as start the 2013 summer session of Seminar Acctg 659 at SDSU, starting Monday, July 8, 2013!
This is part of the syllabus for the course…
The global economy is an economic reality and taxes are a key component of the global economy as they are paid by taxpayers and fund governments. The United States of America (US) has the highest federal corporate tax rate of any OECD country. The highest US corporate income tax rate is 35% and the highest US federal individual tax rate is 39.6%. When you factor in state income taxes, the corporate and individual tax rates are even higher than these amounts if the US person is subject to state income taxes. Taxpayers have a moral and ethical obligation to pay the appropriate amount of taxes no more, no less.
As students learned in Accounting 321 and Accounting 503, taxation is complex and that understanding the US tax rules is critical to informed decision-making for US taxpayers. This course is the comprehensive study of the federal US tax rules as they apply in an international tax context. Topics include: taxation of US persons; taxation of non-US persons; source of income; FDAP income and withholding; inbound taxation; outbound taxation; foreign tax credits; the role of tax treaties; US anti-deferral regimes and transfer pricing.
Course Objectives: The primary objective is to help you understand the US International Tax rules. You will gain an in-depth understanding of the fundamentals of the US tax law in an international context and apply that understanding with international tax planning concepts. The focus of this course is the US federal income tax rules as it relates to international and cross-border transactions.
You will also use and develop higher-level skills such as the ability to analyze, synthesize and critically evaluate information and rules and then to communicate that critical learning to others in an informative, constructive and ethical manner. ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ++
Class | Date (2013) | Topic | Reading |
1 | July 8 | Introduction Course Overview Residency, Sec. 911 |
Code: 871-877, 881-885, 911 and Regs IRS Form(s): 1040NR, 2555, 8938, TDF90.22-1 |
2 | July 10 | Jurisdiction to Tax Scheme of Taxation |
Code: 7701(b) and Regs. Text: pp 16-60 (¶ 1070-1225) |
3 | July 15 | Source of Income | Code: 861-865 and Regs. Text: pp 76-140 (¶ 2000-2245) Case: Wodehouse (¶ 4015) |
4 | July 17 | Trade or Business FDAP Withholding |
Code: 871-875, 881-885, 1441-2 and Regs Text: pp 141-179, 228-241, 260-276 (¶ 3000-3140, 4000-4045, 4110-4180) Case: SDI Netherlands (¶ 4151) IRS Form(s): W8-BEN, 1042 |
5 | July 22 | Class test 1 (30 minutes) FDAP Earnings stripping Branch Profits Tax |
Code: 163(j), 884(a), 897 and Regs. Text: pp 222-227, 277-292Sec. 897 (¶ 3230-3240, 4185-4275) IRS Forms(s): 1120-F, 5472 |
6 | July 24 | Class test 2 (30 minutes) Foreign Tax Credit and Limitation |
Code: 901-907 and Regs. Text: pp 302-315, 324-325, 331, 336-338, 406-428,664-681 (¶ 5000-5025, 5060, 5075-5080, 5105-5110, 5215-5275, 7000-7070) IRS Form(s): 1116, 1118 |
7 | July 29 | Class test 3 (30 minutes) Tax Treaties |
Code: 894 Text: pp 62-75, 181-220, 242-259, 417-484(¶ 1235-1295, 3160-3220, 4050-4102, 5380-5390) IRS Form(s): 8833 |
8 | July 31 | CFC, Subpart F, 956 | Code: 951-958 Text: pp 485-581(¶ 6000-6190) |
9 | August 5 | CFC-continued, 959, 1248 | Code: 898, 959, 964, 1248, 6038, 6046 Text: pp 584-602, 603-608(¶ 6200-6230, 6240-6245) IRS Form(s): 5471 |
10 | August 7 | Major class test (120 minutes) | |
11 | August 12 | Section 482 | Code: 482 and Regs Text: pp 710-760 (¶ 8000-8175) |
12 | August 14 | Class Presentations |