Income Tax Treaties
Focuses on the role, function and uses of income tax treaties. Examines the general aspects of treaties (policy, legal authority and negotiation), the interpretation of treaties, and a detailed examination of the terms of the US Model Income Tax Convention, the OECD Model Tax Convention, the United Nations Model Double Tax Convention between Developed and Developing Countries, as well as selected provisions of current United States treaties in force. Topics include taxation of investment income (i.e., interest, dividends and capital gains), taxation of license fees and royalties, treaty shopping; limitation of benefits, permanent establishment; taxation of the income of natural persons (i.e., personal services), allocation of income between related parties, non-discrimination toward foreigners and recent treaty developments. Cross-listed with and equivalent to the following course. (Note: no academic credit is awarded for retaking equivalent course.): LLM 350C.