Professor Rebecca Rosenberg
(419) 772 – 2216
Tuesday, Wed., & Thursday: 3-4pm
Taxation of International Transactions: Materials, Text and Problems, by Gustafson, Peroni, and Pugh, 4th Edition, West Publishing, ISBN 978-0-314-91171-1 (2011) (“textbook”)
International Income Taxation: Code and Regulations--Selected Sections (2017-2018) (or more recent version, if available)
Author(s): Professor Richard C. Pugh, Robert J. Peroni, Charles H. Gustafson
Published: 06/23/2017 (or more recent version, if available)
NOTE 1: Portions of the Code and Reg volume listed above are now outdated, due to the changes made by the 2017 Tax Act. Therefore, you may want to get the assigned Code and reg sections online, rather than purchasing the hard copy. Or you can get a hard copy and cross-check against the changes made by the 2017 Act.
I'll give you the international-related provisions of the 2017 Tax Act, in either hard copy or electronic form, so it's not necessary to find a hard copy compilation that already has them.
Note 2: The assigned reading includes portions of the Internal Revenue Code of 1986 (the “Code”) and the accompanying Treasury Regulations (“Treas. Reg.”). You can use the hard copy volume of Code and Treas. Reg. sections listed above under “optional”- CHECKING IT AGAINST THE CHANGES MADE BY THE 2017 ACT - or you can use another printed version of the Code and Treas. Reg.’s – SIMILARLY CHECKING IT FOR UPDATES - or you can obtain the Code and Treas. Reg. sections online for free – just do an online search for the section number and either “Internal Revenue Code” or “Treasury Regulation.” See also the notes above about the changes made by the 2017 Tax Act.
In other words, the assigned reading of the Code and Treas. Reg. sections is mandatory. But you can choose where to get those sections, e.g. by using a hard copy or by getting them online or elsewhere. BECAUSE OF THE MANY CHANGES MADE TO THE INTERNATIONAL PROVISIONS BY THE 2017 TAX ACT, WE’LL NEED TO BE ESPECIALLY CAREFUL TO CHECK FOR CHANGES TO ANY HARD COPY VERSIONS.
Please let me know if you have questions. Email is the easiest way to reach me before the week of Jan. 29.
Reading assignments for the first 2 classes:
CLASS 1: basic overview of international tax: what is international tax, big picture on inbound and outbound, big picture on 2017 Act changes, recurring policy themes, intro to treaties (including model treaties)
Textbook assignments refer to paragraph numbers
“Code” means the Internal Revenue Code
Assignment: Textbook: skim ¶1000-1010
read 1070-1133 (basic policy concepts – we’ll see these policy ideas throughout the course)
read 1235-1250 (tax treaties)
1295 (Treaties and the code)
Code sections: 894(a) (“with due regard” to treaty obligations)
7852(d)(1): Code/treaty interaction
7701(a)(1), (4), (5), (30)
CLASS 2: U.S. vs. Foreign persons: definitions, examples, treaty impact
Textbook: ¶1170-1185 (citizens and indiv residents)
1190, problems 2, 3 – and what if a treaty applies?
1205-1223 (residence of entities)
Code sections: 61(a)
7701(a)(4), (5), (9) and (30)
7701(b)(1), (3), (4), (5), (6) and (7), skim (b)(2)
2016 U.S. Model treaty (see link below): Article 1, just paragraphs 1, 2, and 4; Article 4
The 2016 U.S. Model Treaty can be found at: