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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 potentially adverse effects on domestic tax revenues that the FTC generator can yield, he discusses offsetting temporary regulations issued by the Department of Treasury in 2008 and complications introduced by the regulations themselves. Copyright© 2010 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.
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Rufus Rhoades Commentary on Economic Substance and the Foreign Tax Credit Generator Regs
LexisNexis Tax Advisor -- Federal Topical § 4A:12.02