02260128 - International Tax Law

In contemporary world no business lawyer can ignore tax consequences of his or her acts. In real life, the appropriateness of any conclusion of contract, any company restructuring or any other business action must be tested against tax considerations. This is particularly true in a cross-border context where tax jurisdictions overlap, causing additional burdens but also creating new opportunities.
This course is aimed at providing the students with a working knowledge of fundamental concepts of international tax law, with particular focus on international taxation of income.
Special attention will be given to the OECD Model Tax Treaty as well as, primarily, to French and US domestic rules pertaining to cross-border taxation of income.
In particular, students will be expected to understand the operation of the provisions of the OECD Model Tax Treaty.

3 credits or 1.5 US Crédits