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International Tax (Sanchirico)
Fall 2020   LAW 767-001  

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Meeting Times/Location
MW 3:00PM - 4:20PM

Faculty
Chris William Sanchirico

Samuel A. Blank Professor of Law, Business, and Public Policy; Co-Director, Center for Tax Law and Policy

csanchir@law.upenn.edu
Additional Information

Skills Training
Other Professional Skills:

Grading
15% Participation,
85% Exam

Exam
Multiple Choice,
Short Answer,
In Class,
Partial Open Book (Students may only bring the code/regulations supplement, but it may be marked up and tabbed.)

Satisfies Senior Writing Requirement

No

Location

Class meets online.

Course Continuity
Students are encouraged to stay home if you are ill or experience flu-like symptoms. If you miss a class for any reason, it is still your responsibility to make up the work missed.

I offer the following to students who miss class due to illness:

- If a student must miss class, the student should obtain the notes from classmates, review those notes, and then email the professors for an appointment to go over any questions that remain.

- Please make an appointment to meet with me and I will review/answer questions about what you missed.

Category
Upper-Level

Credits
3.0

International taxation plays an increasingly central role in the modern global economy. It is among the most salient policy issues of the day, and one of the chief points of contention between the U.S. and its trading partners. Moreover, it is a primary determinant of the business structures of the most prominent companies in the world, including major US multinationals like Apple, Alphabet, and Cisco. This basic course on international taxation will focus on both the U.S. taxation of U.S. persons engaged in international activities (outbound taxation) and the U.S. taxation of foreign persons engaged in U.S. activities (inbound taxation). The three goals of the class are to provide an overview of relevant law with an emphasis on logical structure and fundamental connections, to help students develop their statute/regulation reading comprehension skills, and to identify and wrestle with current salient international tax policy issues.

All classes will take place at the scheduled class time on Zoom. To access the class Zoom, please click on the “Student Zoom Course” link in Canvas. For more guidance about remote learning at Penn Law, please visit https://www.law.upenn.edu/its/docs/remote-learning/.

Course Concentrations

Business and Corporate Law Learning outcomes: Demonstrate a core understanding of business and corporate law; Perform legal analysis in the context of business and corporate law; Communicate effectively on topics related to business and corporate law; Demonstrate an understanding of the interconnection between the world of business and finance and that of business and corporate law, and how they affect other areas of law and society.

International and Comparative Law Learning outcomes: Demonstrate a core understanding of international and comparative law, both substantively and procedurally; Perform legal analysis in the context of international and comparative law; Communicate effectively on topics related to international and comparative law; Demonstrate an understanding of the role of international and comparative law, and their interconnection with domestic law.

International Corporate and Trade Law

Intellectual Property and Technology Law Learning outcomes: Demonstrate a core understanding of intellectual property law; Perform legal analysis in the context of intellectual property law; Communicate effectively on topics related to intellectual property; Demonstrate an understanding of the interconnection between technology and intellectual property, and how they affect other areas of law and society.

Tax Law Learning outcomes: Demonstrate a core understanding of tax law and policy; Perform legal analysis in the context of tax law and policy; Communicate effectively on topics related to tax law and policy; Demonstrate an understanding of how tax law and policy affect other areas of law and business.

Administrative and Regulatory Law Learning outcomes: Demonstrate a core understanding of administrative and regulatory law and the administrative process, including the role of statutory authorization and work of administrative agencies; Perform legal analysis in the context of administrative and regulatory law; Communicate effectively on topics related to administrative and regulatory law; Demonstrate an understanding of the role administrative and regulatory law play in our legal system and in society as a whole.


Textbooks

"International Income Taxation: Code and Regulations, Selected Sections" by Robert J. Peroni
Edition: 2020-2021
Publisher: CCH
ISBN: 9780808054702
Required

"International Taxation in a Nutshell" by Mindy Herzfeld and Richard L. Doernberg
Edition: 12th (2020)
Publisher: West Academic Publishing
ISBN: 9781684673469
Required