International Taxation Certificate 1 Puerto Rico, and all U.S. states except California. Georgetown is also INTERNATIONAL TAXATION authorized separately to deliver online education to students residing in California. For more information on state authorization, including state CERTIFICATE complaint processes and refund policies the university is required to comply with, please visit Georgetown's office of Compliance and Ethics Georgetown offers a Certificate program in the increasingly important web page: https://compliance.georgetown.edu/student-consumer- field of international taxation. information/distance-education The Certificate is open to both U.S. and foreign-trained lawyers, as well as For more information on SARA please visit: https://www.nc-sara.org/ non-attorney tax professionals, and can be completed together with the Tax LL.M. degree (https://curriculum.law.georgetown.edu/llm/llm-llm- Disclosure Regarding Professional Licensure programs/llm-taxation) or on a stand-alone basis. Georgetown Law's online programs, which include the Executive LLM in Taxation, Executive LLM in Securities & Financial Regulation, MSL in The Certificate in International Taxation can also be completed entirely online Taxation, and Certificates in International Tax and State and Local Tax, (http://curriculum.law.georgetown.edu/llm/llm-online-parttime-options). will not lead to professional licensure and will not qualify a student to sit for any state bar exam. Requirements for U.S.-Trained Students and all Online Students: Search LL.M International Taxation Certificate Courses (http:// • All students must take a minimum of 10 specialization credits. curriculum.law.georgetown.edu/course-search/?program=program_89) • Prerequisites: All students must have successfully completed a course in basic federal income taxation or take Georgetown’s LAW 710 v00 Advanced International Taxation (http:// online course, Foundations of Federal Income Taxation, prior curriculum.law.georgetown.edu/course-search/?keyword=LAW to enrolling in the Certificate program. All students must have %20710%20v00) also completed a basic course in corporate taxation in their LL.M Course (cross-listed) | 2 credit hours JD program or complete Corporate Income Tax Law I in their This course is designed for those students that wish to gain a deeper first semester as part of the Certificate program (which would understanding of the effect of certain U.S. rules governing the taxation increase the required number of credits to 12). of U.S. persons doing business overseas and foreign persons doing • Program Course Requirements: 1) U.S. Inbound International business in the United States. The course will cover a broad range of Taxation; 2) U.S. Outbound International Taxation; 3) Tax topics with particular emphasis on the tax consequences of cross-border Treaties; 4) Survey of Transfer Pricing (available online) or reorganizations, liquidations and taxable acquisitions and dispositions. Transfer Pricing: Selected Topics; 5) One additional course The course will cover the tax consequences of outbound transfers of in international taxation (a minimum of 2 credits). Advanced assets, foreign-to-foreign transfers of assets, and inbound transfers International Taxation, Comparative Tax Law, and International of assets. Students will be expected to have a working knowledge of Tax Controversy are available for students completing the corporate taxation, and transactional aspects of subpart F and the Certificate online. foreign tax credit rules. Requirements for Foreign-Trained Students: Prerequisite: Corporate Income Tax Law I (or Corporate Taxation (formerly Taxation II)); International Tax (or U.S. International Outbound • All students must take a minimum of 10 specialization credits. Tax (formerly: U.S. Taxation of Domestic Persons With Activities Outside • Prerequisites: Distance students may complete the Certificate of the U.S)) in International Taxation in conjunction with the LL.M. degree or Recommended: Prior or concurrent enrollment in Corporate Income Tax on a stand-alone basis. All students must have also completed Law II (or completion of Corporate Taxation (formerly Taxation II)). a basic course in U.S. corporate taxation or complete Corporate Income Tax Law I in their first semester as part of the Certificate program (requiring the completion of twelve credits rather than 10 to complete the program). • Program Course Requirements: 1) International Tax (Fall semester); 2) Tax Treaties (Spring Semester); 3) Survey of Transfer Pricing (Fall semester) or Transfer Pricing: Selected Topics (Spring semester); 4) Three additional credits of coursework in international taxation Contact Information To learn more, please contact: Stafford Smiley, Faculty Advisor, International Tax Program Phone: (202) 662-9906 Email Address: Stafford Smiley ([email protected]) Note on State Authorization to offer Online Programs Georgetown Law is a member of the State Authorization Reciprocity Agreement (SARA), which allows online programs that demonstrate compliance with their home state's authorization requirements to enjoy reciprocal authorization in all other SARA states, which include D.C., 2 International Taxation Certificate LAW 757 v01 Comparative Tax Law (http:// LAW 2038 v00 Current Issues in Tax Policy (http:// curriculum.law.georgetown.edu/course-search/?keyword=LAW curriculum.law.georgetown.edu/course-search/?keyword=LAW %20757%20v01) %202038%20v00) LL.M Course (cross-listed) | 2 credit hours LL.M Seminar (cross-listed) | 2 credit hours Provides an introduction to the study of comparative tax law. The This colloquium will offer students an opportunity to examine current tax coverage is broad, touching on many countries and types of taxes, policy issues in depth and at an advanced level, with discussions led by as well as the general legal framework for tax law and tax procedure. policymakers, economists, and other tax experts. The course will discuss Emphasis is on the income tax and, to a lesser extent, value added tax. various current and recent legislative proposals at a detailed level and Focus is on underlying structural differences in legal systems, including examine the economic, tax policy, and political considerations underlying constitutional issues, judicial interpretation of tax laws, judicial and the decisions that have been made in each proposal. This will include legislative anti-avoidance doctrines, different approaches to defining infrastructure, wealth tax, cross-border tax, consumption taxes and income, alternative systems for taxing corporations and shareholders, other politically salient tax policy topics. It will explore the economic and problem areas in the VAT (including international services and and policy literature surrounding the issues of economic welfare and e-commerce). The student completing this course will have a basic competitiveness. The course will also examine issues such as tax understanding of how to approach foreign tax law, and tools to better expenditures, debt vs. equity, cost recovery, and various tax incentives. understand the tax system in the student’s own country. Reading materials generally will be supplied and will include economic and tax policy papers, legislative proposals, and technical explanations. Prerequisite: Federal Income Taxation (formerly Taxation I) and prior or The course is intended to be highly interactive with students discussing concurrent enrollment in either Corporate Taxation (formerly Taxation II) design and policy issues with leading experts in the field. The grade or Corporate Tax Law I. for this course will be based primarily on papers that students submit addressing policy topics discussed by the guest speakers. Useful class LAW 1633 v00 Current Developments in International Taxation Seminar participation will be taken into account as a plus in determining the final (http://curriculum.law.georgetown.edu/course-search/?keyword=LAW grade. There will be no final exam. %201633%20v00) J.D. Seminar (cross-listed) | 2 credit hours Prerequisite: Federal Income Taxation (formerly Taxation I). In 2017 the United States enacted a historic tax reform package that represents the most significant change to the U.S. international tax regime since 1986. Four years later, significant changes to that new system are being proposed. Meanwhile, at the multilateral level, the Organisation for Economic Cooperation and Development (OECD) has proposed major changes to the mechanisms for coordinating different countries’ assertion of tax jurisdiction over income earned cross-border, in order to shift some taxing rights to market countries and impose a globally agreed minimum tax on corporate income. The minimum tax proposals interact significantly with the existing U.S. international tax regime, as well as with the more recent U.S. proposals. This course will study current developments in US international tax policy through a close reading of selected tax regulatory packages associated with the 2017 tax reform. In addition, we will consider the major international tax policy documents published by the OECD and the relationship between the negotiations at the OECD and U.S. international tax policy developments. We will study these documents and the underlying policy considerations, and discuss the impact on U.S. multinational tax planning. We will also speak with government representatives involved in crafting the regulations and negotiating multilaterally. Students will write short papers with respect to the regulatory packages we examine, and write