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 in overview
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.