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International Taxation in the US (LAWS70124)
Graduate coursework level 7Points: 12.5On Campus (Parkville)
About this subject
- Overview
- Eligibility and requirements
- Assessment
- Dates and times
- Further information
- Timetable (login required)(opens in new window)
Contact information
July
Lecturer
David Rosenbloom (Coordinator)
Email: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
Overview
Availability(Quotas apply) | July |
---|---|
Fees | Look up fees |
This subject provides an overview of United States (US) income tax rules for cross-border investments, transactions, and other activities, with specific relevance for Australians investing into the US and for US persons investing into Australia. The subject will incorporate the latest developments in United States international tax rules, including the 2017 provisions of the Tax Cuts and Jobs Act. It will examine rules, regulations, and administrative practices with an emphasis on case decisions new statutory provisions relating to taxation of foreign persons in the US, taxation of US persons investing abroad, the foreign tax credit, controlled foreign corporations, transfer pricing, and US income tax treaties.
The subject will examine the rules contained in the US Internal Revenue Code (Title 26 of the United States Code), as well as regulations, rulings, and other documents produced by the US Treasury Department and the Internal Revenue Service.
Students may find it helpful to consult International Taxation in a Nutshell (13th ed., Herzfeld)(West academic Publishing), but this volume will not be assigned.
Principal topics may include:
- Entity classification rules
- The definition of 'foreign' persons
- The economic substance doctrine
- Source rules
- Statutory rules for taxation of foreign persons
- Taxation of foreign operations of US persons
- Cross-border organisations, re-organisations, liquidations
- US tax treaties
- The foreign tax credit
- Transfer pricing
- Foreign currency.
Intended learning outcomes
This subject provides a detailed understanding of US international tax rules for inbound and outbound investment, including:
- Taxation of portfolio and business cross-border investment
- Transfer pricing
- The foreign tax credit
- Rules regarding controlled foreign corporations and foreign investment companies
- The impact of treaties
Last updated: 17 February 2024
Eligibility and requirements
Prerequisites
Students must meet one of the following prerequisite options:
Option 1
Admission into a relevant Melbourne Law Masters program
Option 2
Admission into the MC-JURISD Juris Doctor
AND
Code | Name | Teaching period | Credit Points |
---|---|---|---|
LAWS50046 | Taxation Law and Policy | Semester 1 (On Campus - Parkville) |
12.5 |
Corequisites
Non-allowed subjects
730746 International Aspects of US Income Tax
LAWS730746 US Corporate and International Tax
Recommended background knowledge
Applicants without legal qualifications should note that subjects are offered in the discipline of law at an advanced graduate level. While every effort will be made to meet the needs of students trained in other fields, concessions will not be made in the general level of instruction or assessment. Most subjects assume the knowledge usually acquired in a degree in law (LLB, JD or equivalent). Applicants should note that admission to some subjects in the Melbourne Law Masters will be dependent upon the individual applicant’s educational background and professional experience.
Inherent requirements (core participation requirements)
The University of Melbourne is committed to providing students with reasonable adjustments to assessment and participation under the Disability Standards for Education (2005), and the Assessment and Results Policy (MPF1326). Students are expected to meet the core participation requirements for their course. These can be viewed under Entry and Participation Requirements for the course outlines in the Handbook.
Further details on how to seek academic adjustments can be found on the Student Equity and Disability Support website: http://services.unimelb.edu.au/student-equity/home
Last updated: 17 February 2024
Assessment
Description | Timing | Percentage |
---|---|---|
Take-home examination
| 16 - 19 August 2024 | 100% |
Hurdle requirement: A minimum of 75% attendance is required. | Throughout the teaching period | N/A |
Last updated: 17 February 2024
Quotas apply to this subject
Dates & times
- July
Principal coordinator David Rosenbloom Mode of delivery On Campus (Parkville) Contact hours Total time commitment 150 hours Pre teaching start date 19 June 2024 Pre teaching requirements Please refer to the Reading Guide on the LMS subject page for confirmation of which resources need to be read and what other preparation is required before the teaching period commences. Teaching period 17 July 2024 to 26 July 2024 Last self-enrol date 24 June 2024 Census date 19 July 2024 Last date to withdraw without fail 2 August 2024 Assessment period ends 30 August 2024 July contact information
Lecturer
David Rosenbloom (Coordinator)
Email: law-masters@unimelb.edu.au
Phone: 13 MELB (13 6352), International: +(61 3) 9035 5511
Website: law.unimelb.edu.au
What do these dates mean
Visit this webpage to find out about these key dates, including how they impact on:
- Your tuition fees, academic transcript and statements.
- And for Commonwealth Supported students, your:
- Student Learning Entitlement. This applies to all students enrolled in a Commonwealth Supported Place (CSP).
Subjects withdrawn after the census date (including up to the ‘last day to withdraw without fail’) count toward the Student Learning Entitlement.
Additional delivery details
This subject has a quota of 30 students.
Enrolment is on a 'first in' basis. Waitlists are maintained for subjects that are fully subscribed.
Students should note priority of waitlisted places in subjects will be given as follows:
- To currently enrolled Graduate Diploma and Masters students with a satisfactory record in their degree
- To other students enrolling on a single subject basis, eg Community Access Program (CAP) students, cross-institutional study and cross-faculty study.
Please refer to the Melbourne Law Masters website for further information about the management of subject quotas and waitlists.
Melbourne Law School may reserve places in a subject for incoming international cohorts or where a subject is core to a specialisation with limited alternate options.
Last updated: 17 February 2024
Further information
- Texts
Prescribed texts
Specialist materials will be made available via the LMS in the pre-teaching period.
- Related Handbook entries
This subject contributes to the following:
Type Name Course Graduate Diploma in International Tax Course Master of Laws Course Master of Public and International Law Course Graduate Diploma in Tax Course Juris Doctor Course Master of Tax Course Master of International Tax Course Master of Commercial Law - Links to additional information
- Available through the Community Access Program
About the Community Access Program (CAP)
This subject is available through the Community Access Program (also called Single Subject Studies) which allows you to enrol in single subjects offered by the University of Melbourne, without the commitment required to complete a whole degree.
Entry requirements including prerequisites may apply. Please refer to the CAP applications page for further information.
Additional information for this subject
If required, please contact law-masters@unimelb.edu.au for subject coordinator approval.
- Available to Study Abroad and/or Study Exchange Students
This subject is available to students studying at the University from eligible overseas institutions on exchange and study abroad. Students are required to satisfy any listed requirements, such as pre- and co-requisites, for enrolment in the subject.
Last updated: 17 February 2024