ACCT 5306
International Income Tax
Summer 2014
INSTRUCTOR: Professor Robert Ricketts
BA 368
834-3180 (office)
OFFICE HOURS:T-TR, 1:00 – 2:00 and by appointment
REQUIRED
TEXT:Practical Guide to U.S. Taxation of International Transactions. Robert J. Misey, Jr. and Michael S Schadewald. (CCH)
OBJECTIVES: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 anunderstanding 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)300
Homework & cases150
Participation 50
500
PARTICIPATION:One component of the participation score is participation in the Rawls Student Research Program (RSRP). You will not receive full participation points unless you receive 3 hours credit from RSRP. A representative from RSRP will explain to the class how to register for RSRP on Wednesday, July 9th.
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.
07/08 / Conceptual framework for international taxation / Ch 9 provided via email07/09 / Overview--U.S. taxation of cross-border transactions / Text, Ch 1
07/10 / Tax jurisdiction / Text, Ch 2
07/11 / Receive Case 1--due Monday 07/14
07/14 / Source of income / Text, Ch 3
07/15 / Foreign tax credit, limitations & loss recapture / Text, Ch 4
07/16 / Deemed paid foreign tax credit / Text, Ch 4
07/17 / In-class case
07/21 / Exam 1
07/22 / Subpart F--limitations on deferral / Text, Ch 5
07/23 / Foreign currency translation & exchange / Text, Ch 6
07/24 / Code Sec 367--outbound transfers / Text, Ch 14
07/25 / Receive Case 2--due Monday, 07/28
07/28 / Accounting for income taxes--ASC 740 / ASC 740
07/29 / GAAP & PRE / ASC 740
07/30 / Exam 2
07/31 / Review Exam 2
08/04 / Planning for foreign operations / Text, Ch 8
08/05 / Planning for foreign operations, continued / Text, Ch 8
08/06 / Review
08/07 / FINAL EXAM