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This course provides an introduction to the fundamentals of US international taxation. Examine US income tax laws and policies relating to the taxation of foreign persons’ investment and business activities in the United States (“inbound”) and US persons’ investment and activities in other countries (“outbound”). Topics include the concept of residence, the source of income and deductions, foreign persons engaged in a trade or business in the United States, withholding taxes, the foreign tax credit, and the US anti-deferral regimes known as Subpart F and PFIC. Notably, this course does not cover transfer pricing under section 482 or transactional considerations under section 367. These topics are extremely complex and warrant separate designated courses to cover them in required detail.
https://www.sps.nyu.edu/professiona...800