ACCT 568T – TAXATION OF FOREIGN BUSINESS OPERATIONS
FALL 2015
Section 14247 [On-Ground] T 6:30 p.m. – 9:30 p.m. BRI 202
August 25 – December 1
Section 14248 [On- Line] M 5:30 p.m. – 6:30 p.m. CA Time
August 24 – December 4
MarshallTALK (Webex Meetings)
Federal taxation of cross-border transactions for individuals, corporations and partnerships.
SYLLABUS
INSTRUCTOR:
MaryAnne Sabido Werner
Assistant Professor of Clinical Accounting
Leventhal School of Accounting
Room 213
Phone 213-821-4144
Email: mswerner@marshall.usc.edu
OFFICE HOURS:
Tuesdays & Thursdays: 5:15 – 6:15 p.m. and by appointment (virtually and
in person appointments available)
EMERGENCY
NUMBERS:
USC Emergencies 740-4321
USC Emergency Information Line 740-9233
USC Information Line 740-2311
KUSC Radio 91.5
REQUIRED
READINGS:
See Blackboard for instructions to access online:
Applicable IRC and Treas. Reg. Sections (On RIA or CCH)
Practical Guide to U.S. Taxation of International Transactions, Robert
Misey and Michael Schadewald (MS). CCH, 10th Edition
United States Model Income Tax Convention of September 20, 1996
LEARNING OBJECTIVES: Upon taking this course, the student will be able to:
1. Identify the tax differences and impact of entity choice and country of incorporation;
2. Determine the U.S. taxation of foreign Individuals and Corporations;
3. Calculate the Foreign Tax Credit and Deemed Paid Credit (including application of
income sourcing rules and expense allocation and apportionment);
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4. Apply the knowledge learned to analyze the applicability and scope of income tax
treaties; and
5. Identify any Subpart F income and other income subject to other anti-deferral provisions
of the Internal Revenue Code.
PROGRAM LEARNING OUTCOMES:
The following are the five Student Learning Outcomes developed for this program by the USC
Leventhal faculty and administration and filed with the AACSB, the accrediting body for
accounting and business schools. This course will deal primarily with learning outcomes #1, #3,
and #5.
1. Technical, Conceptual, Problem-Solving
Students will be competent in and be able to apply discipline-specific knowledge and skills in the
fields of accounting or taxation. This learning outcome includes the development of critical
thinking and problem-solving skills, as well as an understanding of the strategic role of
accounting and taxation in business organizations and society.
 MBT specific—Apply critical thinking and problem-solving skills related to taxation of
individuals, flow-through entities, and corporations. Recognize potential opportunities for
tax savings and tax planning.
2. Professional Development
Students will be able to communicate clearly and strategically, after considering the relevant
audience, situation, and purpose of the communication. Students will demonstrate the ability to
work productively with others to accomplish established goals.
 MBT specific—Convert complex and technical tax terminology into language that
translates to non-technical audiences. Demonstrate strong interpersonal communication
skills that build relationships with clients over time. Document exchanges with careful
attention to word choice, tone, and accuracy.
3. Research/Life-Long Learning
Students will be able to use relevant research databases and academic/professional literature to
gain new knowledge and analyze business situations.
 MBT specific—Use computer-based and paper-based systems to thoroughly research
tax codes, tax law, rulings and interpretations. Use knowledge to be able to adjust to
changes in tax law over time.
4. Ethical Principles and Professional Standards
Students will be able to apply ethical principles and professional standards in analyzing
situations and making informed decisions.
 MBT specific—Demonstrate understanding of and apply consistently the ethical
principles and professional standards related to the profession. Show the ability to
express and follow rules of independence and the highest sense of professional ethics.
5. Globalization and Diversity
Students will be able to demonstrate an international perspective and appreciation for diversity
and cultural differences, along with their significance in global business.

MBT specific—Explain taxing policies related to foreign business operations of
US individuals/corporations and US business operations of foreign
individuals/corporations.
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For online students only
MARSHALL SCHOOL OF BUSINESS ONLINE LEARNING PLATFORM
Weekly activities may include reading assignments, pre-recorded lectures,
homework assignments,and weekly MarshallTALK live video discussion sessions. It is
estimated that students will spend approximately 9 hours per week outside of the classroom to
complete each week’s materials in a 3-unit course.
New students are encouraged to participate in the Orientation Week activities in order to learn
how to use the online tools available to them before the official start of class.
Our online courses follow a “flipped classroom” model in which students are required to
complete all of the reading assignments, pre-recorded lectures, and Bb assignments at their
own pace (i.e.asynchronously) prior to attending the “real time” (i.e. synchronous) MarshallTALK
video discussion forum, where they will interact with one another and with faculty to apply the
concepts they’ve learned throughout the week.
Students are required to complete all asynchronous online content activities as well as
to participate in the synchronous MarshallTALK live video discussion sessions each
week. Check the course syllabus for dates and times and only register for this class if
you can complete all class work independently and log on to the weekly interactive
MarshallTALK sessions.
Blackboard (Bb)
Blackboard is the primary learning management system currently used at USC and may be
accessed at https://blackboard.usc.edu. From the Bb Course Home Page, students can access
their course syllabus, identify readings, submit assignments, and review grades. They can also
access links to the other platforms used in this course. General questions regarding course
material, content, or procedures should be addressed during MarshallTALK sessions so that
faculty responses may benefit all class members.
Pre-Recorded Lectures
The Pre-recorded lectures enables students to asynchronously view faculty lectures, classroom
discussions and other integrated course content. The Pre-Recorded lectures are organized into
weekly sessions that correspond to the course syllabus and are designed to be taken in the
order they appear.
MarshallTALK
Students and faculty will meet online in real time at a pre-determined date and time each week
in MarshallTALK, a live video discussion forum. MarshallTALK allows students to apply the
content they have learned thus far in the course with their peers and to ask questions of faculty
face-toface. A link to this platform will be found in Bb.
Readings should be done in advance of MarshallTALK sessions. Links to join the weekly
MarshallTALK sessions will be posted in Blackboard. This is your opportunity to have live
discussions with your professor and classmates. Participating in these sessions is not
optional; rather, it is required to meet the minimum number of contact hours for this
course. Students who miss the live sessions consistently or frequently will not be
allowed to pass the course.
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SYSTEM REQUIREMENTS
The following equipment is required to successfully participate in this online course:
• Computer
• Headset or built-in speakers & microphone
• HD Webcam
NOTE: Students using MacBook Pro and MacBook Air computers with retina display may
need to use an external webcam in order to fully participate in the MarshallTALK sessions
(powered by WebEx).
• High speed Internet connection
Students must be able to access at least one of the following browsers:
• Internet Explorer 9.x and above on PCs
• FireFox 3.6 and above on PCs
• Safari 3.6 and higher on Mac (only)
• Firefox 3.x and higher on Mac
• Google Chrome
TECHNICAL SUPPORT
• For Blackboard Support:
USC Information Technology Services:
Call (213) 740-5555 or email consult@usc.edu.
For more information, visit their website at: http://www.usc.edu/its/
• For Virtual Classroom Support:
Email marshall.talk@marshall.usc.edu
• For MarshallTALK (WebEx) Support:
Go to: http://www.webex.com/test-meeting.html
• For MyMarshall Support, USC Marshall:
Call (213) 740-3000 Monday through Friday, 7:00am to 6:00pm PST
or visit their website at: http://msbhelp.usc.edu
• For additional campus-based computer support:
o USC Information Technology Services (ITS) Customer Support Center
http://itservices.usc.edu/csc/
o For Computer Repairs: USC Bookstore Service Department
http://uscbookstore.com/t6-computer_repair.aspx
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GRADING:
QUIZZES
MIDTERM EXAM
FINAL EXAMINATION
HOMEWORK & PARTICIPATION
(Marshall TALK for online)
RESEARCH CASE
TOTAL
POINTS
150
250
300
150
150
1,000
GRADING STANDARDS:
We adhere to the USC Leventhal School of Accounting and Marshall School of Business
grading standards for graduate programs. In general, final course grades at the graduate level
in a core course average approximately B+ (3.3), but may vary based on class performance.
For elective courses, the class average is usually higher--approximating 3.5, which is between a
B+ and an A-. You must receive a C or better to pass a required class, and you must have an
overall B average (3.0 minimum) in order to graduate from USC. . The graded elements of this
course are listed in this syllabus along with information about how they will be evaluated.
CLASSROOM AND GRADING POLICIES:
1. Class attendance and participation is important in developing a coherent view of the
materials covered in the course. Students should be prepared to discuss the materials
assigned for each class. Lack of preparedness will impact your homework and participation
grade.
2. Homework problems will be posted in blackboard for the topic discussed. Students should
be prepared to present answers to the homework problems, which will be presented and
discussed at the beginning of the class session following the lecture on that topic. [For
online class, homework will be presented during the MarshallTALK (Webex meeting)
Monday after the ground class]. Homework problems will not be collected, but your
homework and participation grade is based on advance preparation of the problems and
effective presentation when called upon.
3. Four quizzes (similar to the homework problems) will be given during the course, as
indicated on the syllabus. Quizzes will be taken online through Blackboard. The instructions
and the quizzes can be found under Blackboard’s “Assignments” tab. Quizzes will be
discussed in class immediately after they are due, and must be completed prior to the
class discussion to receive credit for the quiz.
4. Both examinations will be “open book” (Code, Regs, slides, notes, and assigned readings).
Both classes will take the examination at the same time. The ground class will take the
exam in the classroom. The online class will take the examination in Blackboard.
Instructions will be posted.
5. The research paper will be evaluated based on content as well as on the effectiveness of
your communication. This includes grammar, spelling, organization, and other essentials of
effective writing. The topic will be posted in Blackboard.
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6. The class lecture will be recorded and posted on Blackboard. For “on ground students”, the
recordings are for study purposes only and are not a substitute for class attendance.
7. Attendance in all classes is expected and missed class attendance will result in lower class
participation grade.
8. Make up examinations will generally not be given, except in the case of a documented
medical problem. All students must take the final exam as scheduled unless an incomplete
contract has been previously approved according to Leventhal School of Accounting rules.
ACADEMIC CONDUCT
Students enrolled in any class offered by the Leventhal School of Accounting are
expected to uphold and adhere to the standards of academic integrity established by
the Leventhal School of Accounting Student Honor Code. Students are responsible for
obtaining, reading, and understanding the Honor Code System handbook. Students
who are found to have violated the Code will be subject to disciplinary action as
described in the handbook. For more specific information, please refer to the Student
Honor Code System handbook, available in class or from the receptionist in ACC 101.
PLAGIARISM
Plagiarism – presenting someone else’s ideas as your own, either verbatim or recast in
your own words – is a serious academic offense with serious consequences. Please
familiarize yourself with the discussion of plagiarism in SCampus in Section
11, Behavior Violating University Standards https://scampus.usc.edu/1100-behaviorviolating-university-standards-and-appropriate-sanctions/. Other forms of academic
dishonesty are equally unacceptable. See additional information in SCampus and
university policies on scientific misconduct,http://policy.usc.edu/scientific-misconduct/.
SUPPORT SYSTEMS
A number of USC’s schools provide support for students who need help with scholarly
writing. Check with your advisor or program staff to find out more. Students whose
primary language is not English should check with the American Language
Institute http://dornsife.usc.edu/ali, which sponsors courses and workshops specifically
for international graduate students.
The Office of Disability Services and Programs
http://sait.usc.edu/academicsupport/centerprograms/dsp/home_index.html provides
certification for students with disabilities and helps arrange the relevant
accommodations.
If an officially declared emergency makes travel to campus infeasible, USC Emergency
Information http://emergency.usc.edu/ will provide safety and other updates, including
ways in which instruction will be continued by means of blackboard, teleconferencing,
and other technology.
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Discrimination, sexual assault, and harassment are not tolerated by the university. You
are encouraged to report any incidents to the Office of Equity and
Diversity http://equity.usc.edu/or to the Department of Public
Safety http://capsnet.usc.edu/department/department-public-safety/onlineforms/contact-us. This is important for the safety whole USC community. Another
member of the university community – such as a friend, classmate, advisor, or faculty
member – can help initiate the report, or can initiate the report on behalf of another
person. The Center for Women and Men http://www.usc.edu/studentaffairs/cwm/ provides 24/7 confidential support, and the sexual assault resource center
webpage sarc@usc.edu describes reporting options and other resources.
STATEMENT ON RETENTION OF PAPERS FROM THE CURRICULUM OFFICE
According to the Guidelines on Documents Retention, University policy requires that final exams
and all other grade work which affected the course grade be kept for one year. Other papers or
work that instructors hand back but that students fail to pick up can be held for one month.
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SCHEDULE – ACCT 568T – FALL 2015
Class
ONLINE
1
Dates
Aug 24
Aug 25 for
ground
class
Topic / Assignment
SUBMIT
On-Line ONLY- Introduction to Class
TOPIC 1: Introduction / Double Taxation and Foreign Tax
Credit Overview
Text Chapter 1
2
Aug 31 for
online
class
Sept 1 for
ground
class
Sept 14
for online
class
3
Sept 8 for
ground
class
Sept 14
for online
class
4
TOPIC 2: Foreign earned income exclusion for citizens
and residents aliens employed abroad/ Foreign Tax
Credit Individual/ Choice of Entity and country
Text Chapter 2 & 8
Code: §911
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC 1
& 2***
TOPIC 3: Foreign Tax Credit Overview – Corporation/
Indirect and Direct Credit /Source of Income
Text Chapter 3
Code: §§ 901, 902, 78, 861 – 863, 865
Regs: §§ 1.901, 1.902, 1.863-3
Other: Form 1120, pgs 1-4
Form 1118
Sept 15
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
for ground 3***
class
TOPIC 4: Source of Income continued/Allocation and
Sept 21
Apportionment of Expenses
for online
class
Text Chapter 3
Code: §864
Regs: §§ 1.861-8, 8T, 9T(a)-(g), 10T(e), 11, 11T, 12T(c), 17
QUIZ #1 on
Topics 3 &
4 DUE
MIDNIGHT:
Sept 20 for
ground
class
Sept 27 for
online
class
8
5
Sept 22
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
for ground 4***
class
Review Quiz # 1
Sept 28
for online
class
TOPIC 5: Allocation and Apportionment of
Expenses/Foreign Tax Credit – Corporation
Text Chapter 3 and 4
Code: §§ Same as above and 902
Regs: §§ Same as above
6
7
Sept 29
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
for ground 5***
class
Review Quiz # 2
Oct 5 for
online
class
TOPIC 6: Foreign Tax Credit - Limitation
Oct 6 for
ground
class
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
6***
Oct 12 for
online
class
8
9
Text Chapter 4
Code: §§ 904
Regs: §§ 1.904-1
TOPIC: Foreign Tax Credit Problems/Review
Be prepared to present answers to posted review problems
October
13 for
ground
class &
online
class
MIDTERM EXAM –
October
20 for
ground
class
TOPIC 7: Currency translation; earnings and profits
Both classes will take the examination at the same time. The
ground class will take the exam in the classroom.
The online class will take the examination in Blackboard
Tax Treaties/Dual Consolidated Losses
9
QUIZ #2 on
Topic 5
DUE
MIDNIGHT:
Sept 28 for
ground
class
October 4
for on-line
class
October
26 for
online
class
10
Oct 27 for
ground
class
Nov 2 for
online
class
11
Nov 3 for
ground
class
Nov 9 for
on-line
class
11
Nov 10 for
ground
class
Nov 16
for online
class
Text Chapter: 6, 12, and 13
Code and Regs Section 312
Treas Reg 1.964-1T, Section 985 -988
United States of Model Income Tax Convention of September 20, 1996
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
7***
TOPIC 8: Controlled Foreign Corp/Subpart F
Income/956/PFIC
Text Chapter 5
Code: §§ 951, 954, 956-958
Regs: §§ 1.951, 954, 956 - 958
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
8***
TOPIC 9: Subpart F continued/Allocation of Income and
Deductions/ Transfer Pricing
Text Chapter 5 and 13
Code: Same as above
Regs: Same as above
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
9***
TOPIC 10: Taxation of Foreign Taxpayers (Individual and
Corporate)
Text Chapter 9
Code: §§ 864(b)(c)
Regs: §§ 1.864
QUIZ # 3 on
Topics 8 & 9
DUE
MIDNIGHT:
Nov 10 for
ground class
Nov 16 for
online class
12
Nov 17 for
ground
class
***PRESENT POSTED HOMEWORK PROBLEMS TOPIC
10***
Review Quiz # 3
Nov 23 for
online
class
TOPIC 11: Firpta/Branch Level Taxes
Text Chapter 10
Code: §§ 897, 884
Regs: §§ 1.897, 884
10
13
Nov 24 for
ground
class
Review Quiz #4
Topic 12: Formation, Reorganization and Disposition of
Foreign corporations/ Post Mid-Term Review
Nov 30
for online
class
Text Chapter 14
QUIZ # 4 on
Topic 11
DUE
MIDNIGHT:
Nov 24 for
ground class
December 6
for on-line
class
14
Dec 1 for
ground
class
Topic 13: International Tax Practice and Procedure
Text Chapter 16
Dec 7 for
online
class
15
Dec 8 for
ground
class
Review
16
Dec 15
FINAL EXAM
(In Class)
Both classes will take the examination at the same time, The
ground class will take the exam in the classroom
The online class will take the exam in Blackboard
11
Research
Case DUE
MIDNIGHT
DEC 1