Friday, November 1, 2013
Courtney Gesualdi (Ropes & Gray, Boston),
After PPL: How to Bring Congressional Intent Back to the Foreign Tax Credit Applicability Decision, 72 Tax Notes Int'l 355 (Oct. 28, 2013):
Courtney Gesualdi argues that the development of cases involving the foreign tax credit has caused a separation between the intent of section 901 and how it has come to be applied by the courts; Gesualdi offers suggestions to help guide the courts in cases similar to PPL v. Commissioner.
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