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

Economic Substance Codification and Multinational Cross-Border Transactions
Posted on 23 Jun 2010 by Robert Jennings and Elizabeth Sweigart

U.S. multinationals need to focus on the codification of the Economic Substance Doctrine in the recently enacted Health Care and Education Reconciliation Act of 2010, P.L. 111-152 (H.R. 4872) ... U.S. multinationals with contemplated or pending transactions... 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