TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

A Member of the Law Professor Blogs Network

Tuesday, August 27, 2013

Dolan: The Foreign Tax Credit Diaries -- Litigation Run Amok

Tax Analysys Logo (2013)Kevin Dolan (Shearman & Sterling, Washington, D.C.; Former Associate Chief Counsel (International), IRS), The Foreign Tax Credit Diaries -- Litigation Run Amok, 71 Tax Notes Int'l 831 (Aug. 26, 2013):

In a pretend brief, Kevin Dolan explains to a pretend judge why the government's arguments regarding whether foreign taxes must be deducted in determining profit motive in Compaq Computer Corp. [277 F.3d 778 (5th Cir. 2001)] and IES Industries Inc. [253 F.3d 350 (8th Cir. 2001)] are incorrect.

All Tax Analysts content is available through the LexisNexis® services.

http://taxprof.typepad.com/taxprof_blog/2013/08/dolan-.html

Scholarship, Tax, Tax Analysts | Permalink

TrackBack URL for this entry:

http://www.typepad.com/services/trackback/6a00d8341c4eab53ef01901f082d71970b

Listed below are links to weblogs that reference Dolan: The Foreign Tax Credit Diaries -- Litigation Run Amok:

Comments