TitleDate
T536 Course ContentOct 13, 2011 Listen
OVERVIEW OF PRAC OF INTL TAX Winter 2013Oct 13, 2011 Listen
INTRO CaseStudy Engineering Construction Contract and AnalysisOct 13, 2011 Listen
The Indirect Foreign Tax Credit--What It AccomplishesOct 13, 2011 Listen
ECONOMICS OF TAX SPARINGOct 13, 2011 Listen
Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planningOct 13, 2011Watch
Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of TaxationOct 13, 2011Watch
Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC CaseOct 13, 2011Watch
Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings CaseOct 13, 2011Watch
Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereofOct 13, 2011Watch
Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuringOct 13, 2011Watch
Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added TaxOct 13, 2011Watch
Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5Oct 13, 2011Watch
Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6Oct 13, 2011Watch
Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21Oct 13, 2011Watch
Audio Session 1: (i) Introductory Comments, (ii) an In-Class Case Study to demonstrate what "international tax planning" is, and (iii) Methodology. The Case Study demonstrates what bad can happen if there is no planningOct 13, 2011 Listen
Audio Session 2: (i) Methodology, (ii) Ethics and Risks, (iii) Jurisdiction, (iv) the Sanctity of the Separate Legal Entity, and (v) Residency and Basis of TaxationOct 13, 2011 Listen
Audio Session 3: (i) Jurisdiction Case, (ii) Residency and Basis of Taxation, (iii) Classes of Income and Source, (iv) Elimination of Double Taxation, (v) Khoo Holdings Case, and (vi) ABC CaseOct 13, 2011 Listen
Audio Session 4: (i) Forms of Doing Business in Another Country, (ii) Consolidated vs Separate Entity Taxation, (iii) Governmental Incentives including Tax Sparing, and (iv) Discussion of Khoo Holdings CaseOct 13, 2011 Listen
Audio Session 5: (i) Local Entity Participation Requirements, (ii) Tax Effective Locations including discussion of the Indo-Foods Case, and (iii) Discussion of ABC Case Study Facts and implications thereofOct 13, 2011 Listen
Audio Session 6: (i) General Anti-Avoidance Rules/Substance vs Form, and (ii) transfer pricing. For (i), a framework is presented for analyzing such situations. For (ii), a case study is presented for understanding value and structuringOct 13, 2011 Listen
Audio Session 7: (i) ABC Case Facts and implications including discussion of approaches to transferring intangibles and tangibles across border as well as some implications of using "check-the-box entities", and (ii) Value Added TaxOct 13, 2011 Listen
Audio Session 8: (i) Tax Treaty Introductory Matters as well as Articles 1-4, and (ii) initial discussion on Article 5Oct 13, 2011 Listen
Audio Session 9: (i) Follow-up Discussion on Article 4 Residency regarding the Japan-US tax teaty, and (ii) Tax Treaty Articles 5 and 6Oct 13, 2011 Listen
Audio Session 10: (i) Follow-up Discussion on Article 6 and US Code section 897, and (ii) Tax Treaty Articles 7–13, 15 and 21Oct 13, 2011 Listen