| PART I: BASIC PRINCIPLES |
| Tax
Jurisdiction |
| Source of Income Rules |
| |
| PART II: U.S. TAXATION OF FOREIGN INCOME |
| Foreign Tax
Credit |
| Deemed Paid Foreign Tax Credit |
| Transfer
Pricing |
| Anti-Deferral Provisions |
| Cross-Border
Reorganizations |
| Export Benefits |
| Foreign Currency
Translation and Transactions |
| Anti-Avoidance Provisions Governing Foreign Corporations |
| Tax
Treaties |
| Planning for Foreign Operations |
| |
| PART III: U.S. TAXATION OF FOREIGN PERSONS |
| Foreign Persons
Investing in the United States |
| Foreign Persons Doing Business in the United States |
| Planning for
Foreign-Owned United States Operations |
| |
| PART IV: INTERNATIONAL TAX PRACTICE AND PROCEDURE |
| International
Tax Practice and Procedure |