(formerly Federal Taxation of Foreign Income and Foreign Transactions) The class will cover the federal income tax treatment of non-U.S. persons, non-U.S. income of U.S. citizens and residents, and international transactions. We will also discuss international consensus and formal agreements on matters of tax law. We will study the jurisdictional bases for U.S. tax, the source of income and allocation of deductions, different rules applicable to business and non-business income, and the foreign tax credit. We will also consider the U.S. approach to taxing international transactions involving related and unrelated taxpayers, including the problem of transfer pricing and the concept of the controlled foreign corporation. Prerequisite: 270 Federal Personal Income Taxation.