Inbound transactions occur when foreign parties conduct business in the United States or make U.S. investments.
Outbound transactions occur when U.S. parties conduct business abroad or make foreign investments.
For both inbound and outbound transactions, knowledge of certain generic topics is crucial. Thus, this course begins with coverage of generic topics such as the concept of jurisdiction, tax treaties, source of income, and allocation and apportionment of deductions. As noted above, these topics are relevant to both inbound and outbound transactions. Inbound transactions are covered next, including the taxation of foreign parties and the tax consequences when foreign parties dispose of U.S. real estate. Thus, outbound topics are covered last and include the foreign tax credit, U.S. individuals working abroad, foreign sales corporations, and controlled foreign corporations.