Prerequisites: Taxation or permission to waive the prerequisite by the instructor.

Exam Type: One-Day Take Home

This course will cover the basic federal income tax concepts, policy and law relating to taxation of foreign persons with U.S. activities and U.S. persons with foreign activities. The course will discuss long-standing aspects of federal income tax law, as well as rules enacted in 2017 central to that year’s federal income tax reform. We will discuss Moore v. United States, the Supreme Court case involving an element of the 2017 tax reform. In our global economy, federal income tax law relating to cross-border activity affects many business and investment decisions. The course would be of interest to future tax lawyers and transactional lawyers as well as those interested in statutory interpretation.