Int'l Tax Treaties

Course (LEX 7416) ~~and Seminar (LEX 8361)~~

This course (2 credits) will be taught in the summer session, 2010. The class meets from 4:00 p.m. to 6:00 p.m. in Room 2261, beginning on May 25 and ending on July 6.

Exam talk. The exam was given onTuesday, July 13 in Rm 1550. I have finished grading and have submitted the grades. The grades are final; I included class participation in setting the curve. The grades were posted on Monday, July 19. The grades ranged from a high of A+ to a low of B.

Course Materials. I have posted below a syllabus and introductory memo and the course materials. The course materials are password protected. Students in the course will have access to the course materials after receiving the password. I also have had copies printed, which will be available at cost from my secretary. The cost at $21. If you want to order a copy, please notify my secretary, Olive Hyman, at (313) 577-0088 or olive.hyman@wayne.edu. The printed materials will be available on Monday, May 24, 2010.

Introductory Memo (Summer 2010)

Syllabus (as of May 18, 2010)

Planning Problem Assignments

Assignments

Reading Assignments: Note: To open the pdf files for each class, you will need to know the password, which is case sensitive. Call my Secretary, Olive Hyman, at 7-0088 for the password or get it from me in class.

The assignment for the first class is to read the materials for Class #1 posted below. Those materials are NOT password protected at this time.

Course Pak. I have arranged for the printing of the entire set of tax treaty materials, which I will be selling at cost ($21). You can buy a course-pak from my secretary (3rd fl., new building, west wing, 2d cubicle) with cash or check (made out to Michael J. McIntyre). I will also bring copies to the first class, Tuesday, May 25, 2010.

Cover, Tax Treaty Materials
Tax Treaty Materials (2010) (password protected)

Additional Course Materials by Week (Summer 2010)

Classes 1 & 2: Legal Nature of Tax Treaties
Class 3: Treaty Benefits
Classes 4 & 5: Permanent Establishment and Business Profits

OECD Commentary on Article 5
OECD Proposal
UN Proposal on Article 14
Philip Morris Case (2002), Italian S. Ct., translated by Dr. Marco Greggi, University of Ferrar

Classes 6 and 7: Investment and Other Income
Class 8: Tax Planning Problems, 1-3
WClass 9: Services Income
- OECD, Discussion Draft on the Application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention (2010).
Class 10: Double Taxation Relief
Class 11: Information Exchange
- McIntyre, Identifying the New International Standard for Effective Information Exchange
- UN Report on Revision of Article 26
- UN Proposed Commentary, para. 1-3 (skim)
- UN Proposed Commentary, para. 4-7 (skim)
- Geneva Slides (2007) 2x, 6x
- Article 26 OECD (2005)
- Levin bill to required disclosure of beneficial owners of corporate shares
Class 12: Dispute Resolution
- UN Dispute Resolution paper
- McIntyre paper
- US-France Protocol (2009)
- US-France Memo of Understanding (2009)
Class 13: Tax Planning Problems, 4-6

For access to my Taxation and Development (TAD) website, with extensive materials on tax treaties, please click here.

To access the pdf files on this website, please download the most recent free copy of Adobe Acrobat Reader by clicking on the button above.

A Student's Guide to Tax Courses at Wayne Law School, by Professor Michael J. McIntyre (Some information and advice about the tax offerings at the Law School for students considering law school courses in the tax field).

design