An International Tax Guide for Professors Taking Non-U.S. Sabbaticals - John R. Dundon II, Enrolled Agent
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An International Tax Guide for Professors Taking Non-U.S. Sabbaticals

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

An International Tax Guide for Professors Taking Non-U.S. Sabbaticals

An International Tax Guide for Professors Taking Non-U.S. Sabbaticals

Michelle Dhanda (J.D. 2010, Suffolk) published, International Taxation: A Guide for Academics Abroad, 32 Suffolk Transnat’l L. Rev. 701 (2009). Here is part of the Introduction:

Academics are one group who consistently travel to other nations, and their tax burden is relatively heavy. Once preparation for an academic career is complete, however, academics abroad can take advantage of one very important tax benefit: income exclusion for U.S. tax purposes.

Further, academics are not required to pay foreign taxes while residing abroad under many bilateral tax treaties negotiated by the Department of Treasury.

Thus, academics may receive one particular benefit that others, even business people, may not. The IRS has not welcomed the idea of academics working abroad, tax-free, because the purpose of this statutory exclusion in section 911 of the tax code was to assist American businesses competing abroad.

Despite the resistance from the IRS, however, public policy and equity are good grounds for continued academic tax exclusion, and the Department of Treasury’s tax treaties support exclusion.

This work explains some of the tax consequences of academic sabbaticals abroad. Specifically:

  • Part II provides a history of the applicable tax law, both congressional and administrative.
  • Part III considers various hypothetical academic situations
  • Part IV demonstrates how academics may benefit from tax laws.
  • Part V summarizes the benefits and burdens of specific travel decisions.

Unfortunately the article is no longer part of the public domain. For more information on this contact me anytime at your convenience.



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