Jeffery M Kadet
LAW T 536
An introduction to practicing taxes internationally with a principal geographical focus on the Asia-Pacific region. The practice of international taxation requires a combination of both knowledge and mental processes. Knowledge includes international tax principles and mechanisms and how various countries implement them. Mental processes include the approaches and skills required to analyze a cross-border business or investment, identify the relevant issues, arrive at alternative approaches that resolve the issues, and help the decision-maker reach conclusions. In particular, the course participants will be learning and using the processes of researching and dealing with international tax problems and opportunities as well as writing some client-style memoranda thereon. This course focuses on international taxation concepts, principles and planning as applied generally in countries around the world and specifically within the Asia-Pacific region. The course is not focused on the US. As such, we will spend little time on US tax law and regulations. Consistent with the course's intent to develop your knowledge and mental processes, you will not be expected to memorize specific tax rules. As such, case studies and other written assignments will be fully open book. Similarly, the final examination will be a take-home exam that allows you to access research sources just as you would if you were performing work for a client.
Student learning goals
General method of instruction
· Lecture with Class Participation · Required and Recommended Readings · Case Studies · Preparation of Written Memoranda
The instructor has worked in this area for over 30 years. During that entire time, he found the area to be like a giant jig-saw puzzle that changes every day. It has been a constant mental challenge that has held his interest. With this in mind, an enthusiastic and creative mind for this type of challenging subject is key.
Class assignments and grading
In addition to required and recommended readings, there will be several assignments during the quarter. One type will require the student to survey the tax rules of several countries or provisions from their tax treaties in order to gain a sense of both what's available and the differences that one can find. Another type of assignment will involve case studies. In both types, some written memoranda will be required. However, the intent is to learn from the process and not to spend significant time writing up the results.
Final grades will be based upon:
· Class Participation (20%)
· Written Memoranda (40%)
· Final Examination (40%)
The examination is fully open book to reflect the real world where you have access to all reference materials. It is more important for you to know what is relevant and where to find it than it is to have memorized it.