Introduction -- Choice of entity -- Choice of country -- Comparative tax systems -- Source-of-income rules -- Tax treaties -- Foreign tax credit -- Rules for controlled foreign corporations -- Rules for foreign personal holding companies -- Passive foreign investment companies -- Earnings and profits -- Export tax incentives -- Bribe- and boycott-produced income -- U.S. possessions -- Formation, reorganization, and disposition of foreign corporations and expatriate transactions -- Citizens and residents abroad -- Section 482 -- Translation of foreign currency -- Taxation of foreign taxpayers -- Dispositions of foreign-owned real estate -- Branch level taxes -- Filing requirements and record keeping