| IRS Closes Technical Loophole to Eliminate Foreign Tax Credit Planning with Stapled Stock, |
CCH Taxation of Global Transactions |
2004 |
| CCA Recasts Sale of Partnership Assets to Trigger Subpart F |
CCH Taxation of Global Transactions |
2003 |
| Allocating Foreign Stock Attributes Through Partnerships Under Subpart F — Planners Beware |
Taxation of Global Transactions |
2002 |
| The Administration’s Corporate Tax Shelter Proposals: What are the Limits of Appropriate Tax Planning |
Tax Management International Journal |
1999 |
| Further IRS Guidance on the Treatment of Section 304 Related Party Sales in the International Setting |
Tax Management International Journal |
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