In this two-volume treatise, Postlewaite and Donaldson cover the United States taxation of foreign persons and foreign income. Volume 1 analyzes outbound transactions, with detailed chapters on the foreign tax credit, the section 911 exclusion for United States citizens working abroad, and controlled foreign corporations. The Fourth Edition features extensive discussion of the extraterritorial income exclusion and the newly finalized regulations relating to outbound transfers of stock and securities.

Volume 2 addresses inbound transactions, with comprehensive chapters on residency classification rules, income sourcing rules, taxation of foreign persons and dispositions of interests in United States real property. This new edition also contains comprehensive chapters on tax treaties and an overview of the new regulations relation to inbound liquidation and reorganization transactions. Each volume also contains new chapters on international partnership transactions, and reflects other new statutes, regulations, rulings, and cases through July 1, 2002.

This two-volume treatise is available only as a set.