CCH Learning Center

Description:
This course focuses on the U.S. jurisdictional system of determining which persons should be taxed and what income is subject to tax although the U.S. system is examined in the context of more generic rules that all countries use to determine jurisdictional authority to tax.

Those rules focus on personal and economic relationships as the means by which countries assert jurisdiction to tax income. However, in some cases, both countries, in applying these rules, have jurisdictional rights to tax the same income.

In those double taxation cases, the Course discusses the unilateral country approaches, e.g., territorial systems, credit systems, and exclusions like the foreign earned income exclusion, to address the double taxation problem, as well as bilateral solutions to the problem, i.e., tax treaties.

In examining all of these approaches, the course takes a closer look at the tests used to define U.S. residents and nonresident aliens "green card" and substantial presence. Finally, the Course examines a number of complementary and competing tax policy objectives that frame the current U.S. jurisdictional tax system.