U.S. International Taxation

This course considers legal and economic issues surrounding the taxation of multinational companies. We examine the rationale for corporate taxation as well as the challenges raised when levying a corporate tax on multinational companies. Topics include principles of international taxation, tax treaties, worldwide and territorial systems of taxation, and the problems associated with establishing the source of income in a global economy, including the erosion of the tax base due to international tax avoidance. We examine tax competition among countries as well as attempts to enhance international cooperation in matters of international taxation.  We also discuss proposals for systemic reform of international tax regimes.