Scope and introduction -- Introduction to tax treaties -- U.S. taxation of the U.S. source non-trade or business income of nonresident aliens and foreign corporations -- U.S. taxation of the personal services income of nonresident aliens -- Organizing and operating a United States business: foreign controlled U.S. corporations, branches, and partnerships -- Organization and operation of foreign branches by U.S. persons: impact of foreign tax credit, sourcing rules, and foreign currency rules -- Organization of foreign corporations and foreign partnerships -- Treatment of actual and imputed dividends to U.S. corporate shareholders of foreign corporations: the indirect foreign tax credit, look-through rules, resourcing rules, and foreign currency rules -- Section 482: transactions between commonly controlled corporations -- Controlled foreign corporations -- Passive foreign investment companies -- Introductions to domestic and foreign taxable and tax-free mergers and acquisitions -- Taxable sale or liquidation of foreign controlled U.S. corporations -- Taxable sale and acquisitions of a foreign corporation: impact of sections 1248 and 338 -- Introduction to cross border acquisitive reorganizations (Including inversions) and spin-offs.