An examination of the various (jurisdictional) bases for imposing tax on the extra-territorial income of persons with an emphasis on natural persons; the meanings ascribed to the various different bases under the Code, some State statutes, some countries; residence status for tax treaty purposes; dual residence; acquisition of status and planning therefor; relinquishment of status and planning therefor; expatriation meaning and departure tax enforceability and planning.

The syllabus will include both theoretical and practical considerations and make use of illustrative examples.