$1.$ What is meant by 'corporate inversion'? And what benefit is derived by U$.$S$.$ companies from this strategy? Does it necessarily change the operational structure or functional location of a U$.$S$.$ company?

$2.$ What are some of the laws put in place by the Tax Cuts and Jobs Act $($TCJA$)$ in $2017$ to offset profit shifting? What specifically do these laws do to recapture income reported outside the

U$.$ S$?$

$3.$ Explain the foreign earned income exclusion? How does the physical presence test come into play regarding this exclusion?

$4.$ There are two bases on which countries typically exercise income tax jurisdictions $-$ connections between the taxpayer and the taxing country $($residence$)$ and connections between the taxpayer's income and that county $($source$).$ Explain and, in doing so$,$ contrast these two approaches to the taxation of international flows of income.

$5.$ What is the idea of capital export neutrality?

$6.$ Briefly explain the significance of the decision in Cook v$.$ Tait.

$7.$ To mitigate or eliminate international double taxation of the foreign income of U$.$S$.$ citizens, the U$.$S$.$ relies on several devices. One way is your answer to #$3$ above. What other ways has the U$.$S$.$ helped its citizens mitigate or eliminate international double taxation of the foreign income? $($hint$-$ one involves the U$.$S and other countries and the other involves reducing the tax obligation on your income tax return$).$

$8.$ Explain what a CFC and PFIC are designed to do $($i$.$e$.,$ their principal purpose$).$

$9.$ Describe the distinction in the U$.$S$.$ taxation of a resident and non$-$resident.

$10.$ Foreign business and investment activities in the U$.$S$.$ are often collectively referred to as

'inbound taxation' As it relates to a foreign taxpayer's U$.$S$.-$source gross income explain what is meant by 'effectively connected income $($ECI$)$ and income that is fixed or determinable annual or periodical $($FDAP$).$ How did FDAP relate to the the Wodehouse and Barba cases?

$11.$ Carlos is an individual citizen and resident of Brazil. His start$-$up company negotiates cooperation with a U$.$S$.$ corporation, which requires him to visit the U$.$S$.$ Does Carlos satisfy the objective substantial presence test of IRC section $7701($b$)(3)($A$)$ in the following cases?

$($a$)$ He spent the $1$st $3$ full months of Year $1$ thru Year $3$ In the U$.$S$.$ Does Carlos meet the substantial presence test in Year $3?$

$($b$)$ He spent $360$ days in the U$.$S$.$ in each of Year $1$ and Year $2$ and the whole month of June in Year $3.$ Does Carlos meet the substantial presence test in Year $3?$