International expansion has been the governing drive of all U.S.-based multinational corporations for many years. Today more and more companies are going international for expansion and survival. This course explains the sourcing of income and the allocation and apportionment of expenses for tax purposes. The sourcing provisions are used to determine the income that is foreign vs. domestic sourced. The sourcing provisions are also used to allocate expenses to various classes of gross income and apportion such expenses between domestic and foreign sources of gross income. The sourcing rules are of interest for purposes of the U.S. foreign tax credit, the earnings of foreign branches, the foreign subsidiaries of U.S. corporations, and the U.S. taxation of foreign taxpayers.