Controls within Content
If controls are directly necessary for the primary tasks of an application (e.g. the "send message" button in a address book app) and there is space left in the content area, put them directly within the content.
Developer
If controls are directly necessary for the primary tasks of an application (e.g. the "send message" button in a address book app) and there is space left in the content area, put them directly within the content.