ACCT 5306
International Income Tax
Summer 2014
INSTRUCTOR: Professor Robert Ricketts
BA 368
834-3180 (office)
OFFICE HOURS: M, 9:30-11:30, 2:30-3:30, and by appointment
REQUIRED
TEXT:
OBJECTIVES:
Practical Guide to U.S. Taxation of International Transactions. 10th
ed. Robert J. Misey, Jr. and Michael S Schadewald. (CCH)
In this course we will study the U.S. income tax framework for taxing
multinational business operations. We will begin with a brief review of
the conceptual framework for international taxation, comparing the
U.S. approach to that used by other countries. We will then turn to an
in-depth analysis of U.S. tax law related to cross-jurisdictional
business activities, followed by an overview of accounting for income
tax liabilities for multinational corporations under GAAP. The course
concludes with a demonstration of how the concepts addressed
throughout the course are integrated into a holistic tax-planning
strategy for multinational operations. Unlike most other countries, the
United States taxes the worldwide income of U.S. citizens and U.S.
corporations.
The objectives of the course are as follows:
1) Develop an understanding of how the U.S. tax system is applied to
multinational operations;
2) Identify and analyze how firms structure their operations in order
to minimize or defer payment of taxes.
3) Students will then be prepared both to practice in the international
tax arena and to participate in the ongoing debate about international
tax reform.
ASSESSMENT: The accomplishment of learning goals will be assessed through
examinations, class discussion, and case analyses. Attendance will be
taken. Final grades for the course will be determined based on the
percentage of total points attained. Total points available with respect
to each assessment practice will be as follows:
Exams (3)
Homework & cases
Participation
300
80
20
400
UNIVERSITY POLICIES
Integrity. Academic dishonesty will not be tolerated. All students are required to adhere
to the Texas Tech University Policy on Academic Honesty. Students using or providing
assistance during an examination will receive an F for this course. Students working on
homework or cases with classmates outside their assigned groups will receive a zero on
the assignment.
Civility in the Classroom. “Students are expected to assist in maintaining a classroom
environment which is conducive to learning. In order to assure that all students have an
opportunity to gain from time spent in class, unless otherwise approved by the instructor,
students are prohibited from using cellular phones or beepers, eating or drinking in class,
making offensive remarks, reading newspapers, sleeping or engaging in any other form of
distraction. Inappropriate behavior in the classroom shall result in, minimally, a request
to leave class.”
ADA Requirements. Classroom accommodations will be made for students with
disabilities, if requested.
Religious Holidays. A student who intends to observe a religious holy day should make
that intention known to the instructor prior to an absence. A student who is absent from
classes for the observance of a religious holy day shall be allowed to take an examination
or complete an assignment scheduled for that day within a reasonable time after the
absence.
Tentative Schedule
The following is a tentative schedule of topics, readings, and assignments. You are
expected to have read all assigned materials each day before attending class.
PART 1: General Framework
08/24
Conceptual framework for international taxation
08/31 Foreign Tax Credit
09/07 No class (but homework will be assigned!)
09/18 Source of Income Rules
09/21 EXAM 1
PART 2: Measurement, Timing & Accounting
09/28 Accounting for Income Taxes
10/05 Subpart F
10/12 Foreign Currency Translation
Code Sec. 367: outbound, inbound & foreign-to10/19
foreign transactions
10/26 EXAM 2
PART 3: Planning
11/02 Transfer Pricing
11/09 Planning for Foreign Operations
11/16 Planning for Foreign-owned U.S. Operations
Taxing Ex-Pats (including domestic ex-pats of foreign
11/23
companies)
11/30 Tax Treaties
12/09 Final Exam
Ricketts, Ch 9
provided online
Text, Ch 4
Text, ¶804
Text, Ch 3
Take home
Handout
Text, Ch 5
Text, Ch 6
Text, Ch 14
Take home
Text, Ch 12
Text, Ch 8
Text, Ch 11
Text, Ch 2
Text, Ch 13
Take home