At the top of this page, you will find links to the reading list and syllabus for the course.

For your information, I have included below a general description of the course, the course meeting time and place, the attendance policy, my office hours, the grading policy for the course, and information for students needing special accommodations.

Course Description

This course will serve as an introduction to the U.S. federal tax aspects of the cross-border flow of capital and labor. At the most basic level, we will explore the distinction, both for income and for estate and gift tax purposes, between a U.S. and a foreign person. We will then compare and contrast the manner in which U.S. and foreign persons (including tax expatriates) are subject to income tax. We will also cover the special tax regimes applicable to investments made by U.S. persons in foreign corporations (i.e., the controlled foreign corporation and passive foreign

investment company regimes) as well as an introduction to the foreign tax credit rules. Throughout the course of the semester we will consider the potential impact of tax treaties on the rules in the Internal Revenue Code.

Course Meeting Time and Place

The course will meet on Mondays, Tuesdays, and Wednesdays from 2:30-3:20 p.m. in Room G12.

Attendance Policy

Regular and punctual attendance at class is required.  Regular attendance is defined as attendance and preparation at not less than 80% of the classes for the semester.  Failure to satisfy this requirement will result in the student being certified out of the course with a grade of “U” (Unsatisfactory).

Office Hours

My office hours are on Mondays and Wednesdays from 10:30-11:30 a.m.  My office is located in Room 305 of the Barco Law Building (on the 3rd floor, in the library).  You may also make an appointment to see me at another time (my telephone number is 412-648-1244), or you can just drop by my office to see if I am available.  You can also e-mail me any questions that you may have.

Grading Policy

The grade for the course will be based on a series of drafting projects. 

Special Accommodations

If you have a disability for which you are or may be requesting an accommodation, you are encouraged to contact both the Associate Dean of Students and Disability Resources and Services, 216 William Pitt Union (412) 648-7890/(412) 383-7355 (TTY), as early as possible in the term. DRS will verify your disability and determine reasonable accommodations for the course. The Associate Dean of Students will oversee the implementation of accommodations.