International and US Taxation---Review of Topics for Final Examination

   

   

   Policy Considerations

   Worldwide v Territorial Jurisdiction

   Capital Export Neutrality

   Capital Import Neutrality

   National Neutrality

   

   Outbound Transactions

   The Foreign Tax Credit

   Business Structure---Corporations vs pass-thru entities

   Classification of entities

   Controlled Foreign Corporations

   Subpart F Income

   

   

   Inbound Transactions

   Trade or Business Income

   Branch Profits Tax

   Investment Income-  FDAP

   Real Property Interests

   

   Transfer Pricing

   Section 482

   OECD

   Penalties and Records

   Advance Pricing Agreements

   

   US Income Taxation

   Sources of Law

   Constitution

   Statutes

   Regulations

   Rulings

   Court Decisions

   

   Structure of the Individual Income Tax

   Gross Income

   Exemptions

   Personal Deductions and Standard Deduction

   Taxable Income

   Progressive rates

   Earned Income Credit

   Alternative Minimum Tax

   

   Business Taxation

   Expenses

   Depreciation and Cost Recovery

   

   Corporate Taxation

   Reorganizations, Mergers and Acquisitions

   Dividends

   Redemptions and Leveraged Buyouts

   Liquidations

   

   Pass thru entity Taxation

   Partnerships and LLCs

   

   Consumption Tax

               Social Security

               Medical Accounts

               Pensions

   

   Wealth Transfer Taxation

   Estate Tax

   Gift Tax