This course examines the U.S. taxation of transactions undertaken by foreign individuals or entities in the U.S. as well as the U.S. taxation of transactions undertaken by U.S. individuals or entities abroad. Major topics that will be covered include determination of the source of income, the taxation of income derived from a U.S. trade or business, the withholding tax regime, taxation of various entities, controlled foreign corporations, the U.S. anti-deferral rules, the U.S. foreign tax credit, taxation of foreign currency transactions and the role of tax treaties.
Prof. Richard Gordon is a Professor of Law, Director of the Financial Integrity Institute, and Associate Director of the Frederick K. Cox International Law Center. Prior to joining the CWRU School of Law, Prof. Gordon practiced international tax law in Washington, D.C., taught at Harvard Law School, and worked at the International Monetary Fund.
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