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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...