1. Describe and diagram the timeline that most businesses use to enter the international markets.
2. With respect to income generated by nonU.S. persons, does the U.S. apply a worldwide or a territorial
approach. Be specific.
3. Discuss the primary purposes of income tax treaties.
4. In international corporate income taxation, what are the uses of the sourcing rules in computing Federal taxable
income?
5. The § 367 crossborder transfer rules seem to counteract other favorable tax provisions that allow the taxpayer to defer gross income, e.g. §§ 351 and 368. What is the rationale for eliminating this deferral? Provide two examples of transactions to which § 367 would apply.
6. Your client holds foreign tax credit (FTC) carryforwards, i.e., it is in an excess credit position. Give at least three planning ideas that the client should implement, so as to free up the suspended FTCs.
