T516 International Taxation II

6-04 Subpart F and Disregarded Entity Issues

An introduction to the practice of US tax law with respect to the conduct by US persons of business and investment outside the US either directly or through non-US entities. This course seeks to strike a balance between the technical detail within the US tax law and the practical application of that law to typical business and investment situations. The goals of the course include: -Achieving familiarity and understanding of the provisions of US tax law relevant to "outbound" investment -Developing skill in applying these provisions of US law to practical business and investment situations Developing an ability to examine an outbound business or investment situation and to identify relevant US tax issues -Learning to analyze the various US issues in order to arrive at conclusions and recommended courses of action, -Developing sensitivity to identify opportunities and risks Contents of Class Sessions