U.S. taxation in the international setting -- Nationality and residence for taxation -- The source of income -- International transfer pricing -- U.S. taxation of foreign persons: passive investment income -- U.S. taxation of foreign persons: taxation of a trade or business -- Income tax treaties -- Inbound base protection measures that backstop inbound taxation -- Outbound U.S. taxation -- Direct foreign investment: the foreign tax credit regime -- Controlled foreign corporations -- Passive Foreign Investment Companies (PFICs) -- Dispositions, liquidations, and reorganizations of controlled foreign corporations and incorporations of foreign branches -- Miscellaneous foreign incentives regimes.
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