Loyola University Chicago

School of Law

International and Comparative Law

382: International Tax

Credit Hours



Federal Income Tax


This course focuses on U.S. income tax issues with respect to the foreign activities of U.S. taxpayers and U.S. activities of foreign taxpayers. Particular emphasis is placed on the corporate taxpayer. Foreign tax systems are not addressed specifically except to highlight differences from the U.S. system. Specific topics include the foreign tax credit, sourcing rules, the "effectively connected" doctrine, the concept of trade or business in the U.S. Code section 482 allocations, subpart F income, and tax treaties. (Brunson)