he application of general rules of federal income taxation to foreign persons and to foreign income of U.S. citizens and residents, including the special provisions applicable only to foreign persons and/or foreign income. The jurisdictional bases for U.S. tax, the source of income, tax situs of property, allowance of expenses and deductions, exemption for income earned abroad, foreign tax credits, reporting and return requirements, and the impact of U.S. tax treaties. The treatment of foreign corporations and businesses, including foreign personal holding companies and the controlled foreign corporation concept. Does not cover the tax laws of any other country or compare U.S. and foreign tax structures or approaches. Prerequisite: Federal Income Taxation (270). Business Organizations (248) would be helpful but is not required. International, International High Tech and High Tech Law Certificate course.