| The Proposed Contingent Nonperiodic NPC Regulations — An Overview |
Journal of Corporate Taxation |
2004 |
| Importing and Exporting Basis and Other Tax Attributes: Do We Need a New System? |
Journal of International Taxation |
2001 |
| IRS Takes a Stand Against “Abusive” Foreign Tax Credit Structures, But Does It Have the Authority? |
Journal of International Taxation |
1998 |
| Tax Court Allows Apportioning Fifty Percent of Cross-Border Sales to Foreign-Source Income |
Journal of International Taxation |
1993 |
| Earnings Stripping Proposal Has U.S. Subs Looking to Replace Parent-Guaranteed Debt |
Journal of International Taxation |
1993 |
| IRS Refines Approach to Cross-Border Related Corporation Sales |
Journal of International Taxation |
1993 |
| An Analysis of the Earnings Stripping Regulations |
Tax Managment International Journal |
1991 |
| Recent Ruling Allows Foreign Tax Credit for Cash Repatriations |
Journal of International Taxation |
1991 |
| Foreign Finance Subsidiaries Are Still Useful After TRA ‘86 |
Journal of International Taxation |
1990 |
| Rev. Rul. 89-72: Foreign Base Company Sales Income Earned by Partnerships |
Tax Managment International Journal |
1989 |