Tax Law

Recent Posts

Economic Substance and the Foreign Tax Credit Generator Regs
Posted on 3 May 2010 by Rufus Rhoades

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... Read More

Practical Tax Considerations Relevant to U.S. Totalization Agreements
Posted on 6 Jul 2012 by Rufus v. Rhoades & Alexey Manasuev

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... Read More

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine
Posted on 5 Apr 2012 by Rufus v. Rhoades & Alexey Manasuev

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... Read More