Economic Substance and the Foreign Tax Credit Generator Regs

In July 2008, Treasury issued Temp. Reg. Section 1.901-2T(e)(5)(iii) designed to shut down what has become known as the "foreign tax credit generator" transaction. In March 2010, Congress finally granted Treasury its wish and codified the "economic substance" doctrine. ... ...

Rufus Rhoades on the foreign tax credit generator, offsetting temporary regulations issued by the Department of Treasury, and the codification of the "economic substance doctrine"

On this edition, Rufus Rhoades, co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, published by LexisNexis Matthew Bender, outlines the purpose and practical impact of the foreign tax credit generator and codification of the "economic substance doctrine." Examining...

Rufus Rhoades on the foreign tax credit generator, offsetting temporary regulations issued by the Department of Treasury, and the codification of the "economic substance doctrine"

On this edition, Rufus Rhoades, co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, published by LexisNexis Matthew Bender, outlines the purpose and practical impact of the foreign tax credit generator and codification of the "economic substance doctrine." Examining...

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine

The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability penalties [ IRC § 6662(b)(6) (20 percent strict...

Further Guidance on Foreign Financial Asset Reporting

[ Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, Chapter 9 (Matthew Bender) .] Virtually all individual taxpayers (and certain entities called "specified domestic entities") are required to report their financial assets...

Practical Tax Considerations Relevant to U.S. Totalization Agreements

Totalization agreements are one of the best kept secrets in the international tax arena. Very few practitioners know they exist, and fewer still know what those agreements do... ... Totalization Agreements: What They Are A totalization agreement is a bilateral treaty between two countries that...