Fall 2010

International Tax – Individuals and Foreign Corporations

Bus 225D – Taxation of individuals with foreign activities, and inbound investment and activities of foreign corporations. Topics
include taxation of US expatriates and foreign nationals, foreign tax credit, tax treaties, foreign-owned US real estate, and issues of
mobile employees.
Prerequisites: Bus 223A, 223C.

Course Objectives – Introduce students to special rules and concepts associated with mobile employees and taxation of foreign
corporations doing business in the US. At the end of this course students will be in a position to (1) understand the key tax technical
impacting expatriates and aliens; (2) recognize the issues associated with foreign corporations doing business in the US; and (3)
understand the multi-jurisdictional impact of these transactions.

Instructor: Carol Rutlen, CPA

Rutlen Associates
650-321-3999
crutlen@rutlen.com

Text: Fundamentals of Int’l Taxation, (2010/2011 Edition) by Bittker and Lokken; published by Warren, Gorham & Lamont.

Office Hours: 20 minutes before and after class and by appointment. Preferred method of communication is email.

Class Location: Techmart, 5201 Great America Parkway, Santa Clara, CA

Classroom TBD
DATE TIME TOPIC READING
Sept 27 6 – 10 pm Overview of Text ¶ 65.1.1 – 65.1.6 IRC § 3401(a)
Taxation of Int’l IRC § 61 Form 673
Transactions PLR 7927002
Oct 4 6 – 10 pm Taxation of US Text ¶ 66.3.1 – 6 Prop. Reg. 1.861-4
Expatriates IRC Sec 911 (Code and Regs) Rev. Rul. 91-58
Optional – IRS Publication 54 Notice 2007-77, 2007-40 IRB 735
TAKE HOME PROJECT DUE OCTOBER 11
Oct 11 6 – 10 pm Foreign Tax Text ¶ 72.1, 72.2, 72.3.1, 72.4.1, 72.4.2, 72.5.1, 72.6.1, 72.6.2, 72.6.5, 72.6.7
Credits Text ¶ 72.13 – 72.14.3, 72.15 – 72.16
Text ¶ 73.1 – 73.4.2, 73.10.1
IRC Sec 901(a), (b), and (c)
IRS Form 1116 and Instructions
TAKE HOME PROJECT DUE OCTOBER 18
Oct 18 6 – 10 pm Other Expat Text ¶ 66.1.1 – 66.1.7, Rev. Rul. 93-86
Issues/Extended 66.1A.1 – 77.1A.7 Rev Rul. 73-529
Business Trip § 162(a)(2) Rosenspan v. US 483 F 2d 905
§ 3401 TAKE HOME PROJECT DUE OCTOBER 25
§ 274
§ 7701(b) Optional – IRS Publication 463
Reg. § 1.162-2 http://us.kpmg.com/microsite/tax/ies/tea/summer2004/stories/ar
Reg. § 31.3121(a)-3 ticle03.htm - Domestic Assignments: Taxability of Expenses
Reg. § 31.3306(b)-2

Oct 25 6 – 10 pm Taxation of § 7701(b) Optional – IRS publications 515 and 519

Foreign Nationals Reg. § 301.7701(b) IRS Forms SS5/W4/W7
Text ¶ 65.1.3, 65.2.1 – 65.2.6 TAKE HOME PROJECT DUE NOV 1
Text ¶ 67.1.1 – 67.1.3, 67.9
Text ¶ 134.1
IRS Form 8854
Nov 1 6 – 10 pm Foreign Persons Skim Text ¶ 67.2.1 – 67.2.5, 67.2.9 – 67.2.10, 67.4.1 – 67.4.3, 67.6.1 – 67.6.5
Investing in the Text ¶ 74.1, 74.2, 74.3.1;
US and Misc. Text ¶ 134.2.1
Alien Issues § 864(c)(6)
§ 871(i)
§ 985
§ 987
§ 989
US Model Income Tax Convention of November 15, 2006 from
http://treas.gov/offices/tax-policy/library/model006.pdf
Franchise Tax Board Publication 1100
Nov 7 6 – 10 pm Treaties/Immigra- US Model Income Tax Convention of November 15, 2006 from
tion http://treas.gov/offices/tax-policy/library/model006.pdf
Text ¶ 66.4
Skim Text ¶65.3.6, 65.4.1 – 65.4.6
Text ¶ 67.4.4, 67.6.9
IRS publication 901
Skim this website http://www.immigrationlaw.com/workvisas.html
Nov 15 6 – 10 pm US Foreign- Text ¶ 65.1.4
Owned Real Text ¶ 67.6.6, 67.7.1 – 67.7.3; 67.7.5, 67.7.8 – 67.7.10
Estate, Anti- Text ¶ 69.1-2, 69.4.1-69.4.4
avoidance Skim Text ¶ 70.1 – 70.1.4
Legislation,
Global Equity
Compensation,
Qualified Plans
for Mobile
Employees
Nov 22 6 – 10 pm Final
Nov 29 6 – 10 pm Review Final and
Planning Tech.
Grading: 50% in class final on Nov 22
10% take home project from Oct 4 class
10% take home project from Oct 11 class
10% take home project from Oct 18 class
10% take home project from Oct 25 class
10% class participation including in-class discussions and presentation of case studies
Take home projects received after the due date will be penalized 50%.

University Policies
Academic integrity
Students are expected to be familiar with the University’s Academic Integrity Policy. Your own commitment to learning, as evidenced
by your enrollment at San José State University, and the University’s Academic Integrity Policy requires you to be honest in all your
academic course work. Faculty members are required to report all infractions to the Office of Student Conduct and Ethical
Development. The policy on academic integrity and other resources related to student conduct can be found at
http://sa.sjsu.edu/student_conduct.

Campus Policy in Compliance with the American Disabilities Act

If you need course adaptations or accommodations because of a disability, or if you need to make special arrangements in case the
building must be evacuated, please make an appointment with me as soon as possible, or see me during office hours. Presidential
Directive 97-03 requires that students with disabilities requesting accommodations must register with the DRC (Disability Resource
Center) to establish a record of their disability.
Special accommodations for exams require ample notice to the testing office and must be submitted to the instructor well in advance
of the exam date.