U.S. TAX PLANNING BY STAFFORD SMILEY PROFESSOR AND FACULTY DIRECTOR GRADUATE TAX (LLM) PROGRAM GEORGETOWN UNIVERSITY LAW CENTER WASHINGTON, DC
This course is devoted to the study of tax planning from the point of view of U.S. taxpayers, including those investing and/or operating outside the borders of the United States (outbound transactions), and of foreign taxpayers investing and/or operating inside the United States (inbound transactions). I expect that you will want to become familiar with the rules applicable to outbound and inbound transactions under the U.S. Internal Revenue Code (the Code), the regulations promulgated under the Code by the U.S. Treasury Department (the Treasury Regulations or Treas. Reg.), applicable administrative pronouncements from the Internal Revenue Service (IRS) and judicial authorities.