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2008

Date	Title
July/August 2008	Subpart F: The Same-Country-of-Manufacture Exception - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 2008 / June 2008	Proposed Subpart F Contract Manufacturing Regulations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 2008	Short-Term CFC Loans May Avoid Code Sec. 956 - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

Date

Title

July/August 2008

Subpart F: The Same-Country-of-Manufacture Exception

- International Tax Journal
Type: Articles
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

May 2008 / June 2008

Proposed Subpart F Contract Manufacturing Regulations

- International Tax Journal
Type: Articles
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

January 2008

Short-Term CFC Loans May Avoid Code Sec. 956

- International Tax Journal
Type: Articles
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

2006

Date	Title
January 1, 2006	CFCs - Sections 959-965 and 1248 - BNA Tax Management Portfolio Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2006	Look-through Treatment for Related Controlled Foreign Corporation Payments - CCH's Law, Explanation and Analysis of the Tax Increase Prevention and Reconcilation Act of 2005 Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

Date

Title

January 1, 2006

CFCs - Sections 959-965 and 1248

- BNA Tax Management Portfolio
Type: Other
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

2006

Look-through Treatment for Related Controlled Foreign Corporation Payments

- CCH's Law, Explanation and Analysis of the Tax Increase Prevention and Reconcilation Act of 2005
Type: Articles
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

2005

Date	Title
2005	¶800 Temporary Incentive for Repatriation of Earnings Clarified - CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005 Type: Other Author(s): Damon Lyon , Lowell D. Yoder Practice Areas & Industries: Tax
2005	¶805 Look-through Treatment for Sales of Partnership Interests Clarified - CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005 Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: Tax

Date

Title

2005

¶800 Temporary Incentive for Repatriation of Earnings Clarified

- CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005
Type: Other
Author(s): Damon Lyon , Lowell D. Yoder
Practice Areas & Industries: Tax

2005

¶805 Look-through Treatment for Sales of Partnership Interests Clarified

- CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005
Type: Other
Author(s): Lowell D. Yoder
Practice Areas & Industries: Tax

2004

Date	Title
November, 2004	American Jobs Creation Act of 2004: Law, Explanation and Analysis - CCH Incorporated Type: Books Author(s): Gregory G. Palmer , Katherine Stenander , Lowell D. Yoder Practice Areas & Industries: Tax

Date

Title

November, 2004

American Jobs Creation Act of 2004: Law, Explanation and Analysis

- CCH Incorporated
Type: Books
Author(s): Gregory G. Palmer , Katherine Stenander , Lowell D. Yoder
Practice Areas & Industries: Tax

2003

Date	Title
August 8, 2003	“Subpart F Repatriation: Distribution Timing is Everything,” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 13, 2003	“Subpart F Hopscotch Rule Permits Targeted Repatriation,” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2003	“Tax Beneficial Finance Structures for Acquiring Foreign Targets,” - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 11, 2003	“Final Brown Group Regs.: Aggregate/Entity Duplicity,” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring2003	“Structures that Reduce Source Country Taxes,” - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 14, 2003	“Final Regulations Apply Subpart F to a CFC's Distributive Share of Partnership Income,” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2003	"From Storefronts to Servers to Service Providers: Stretching the Permanent Establishment Definition to Accomodate New Business Models" - Taxes Type: Articles Author(s): Sandra P. McGill , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 14, 2003	“Look-Through For 10/50 Joint Venture Corporations: Not a Panacea,” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2003	“The Limited Case: A Refresher in Statutory Interpretation,” - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2002

Date	Title
Fall 2002	Final Regulations Address CFC Partner/Partnership Transactions - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September 13, 2002	The Limited, Inc. v. Comr.: Appellate Court Slams Tax Court's Narrow Interpretation of §956 Bank Deposits Exception - Tax Management International Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
June 14, 2002	"The Subpart F Exception for Active Financing Income" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2002	"The Finance Company Exception to Subpart F" - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2002	"The Export Tax Incentive Is Not Dead Yet" - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2002	"All Quiet on the Subpart F Income Front" - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2001

Date	Title
November-December 2001	co-author, "Guidance on the Extraterritorial Income Exclusion" - International Transfer Pricing Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 12, 2001	"CCA 200103031: Does §338(h)(16) Apply to Deemed-Paid Credits?" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax , Tax - Acquisitions & Restructurings
Fall 2001	co-author, "Extraterritorial Income Exclusion: The New Export Tax Incentive" - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 11, 2001	"Planning Techniques Described in the Treasury's Subpart F Study" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 23, 2001	"Analysis of Tax Avoidance Structures Under the Treasury's Subpart F Study" - Tax Management Memorandum Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 2001	co-author, "Seagate: Restricted Stock Gains Are Subpart F Income" - Journal of International Taxation Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 12, 2001	"FSA 200046008: Another Branch Attack" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Pass-Throughs , Tax , Tax - Acquisitions & Restructurings

2000

Date	Title
December 8, 2000	"Prop. Regs. Address the Application of Subpart F to a CFC's Distributive Share of Partnership Income" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Pass-Throughs , Tax
May 2000	“Proposed CTB Regulations Void Branch Elections: Subpart F and Other Consequences” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Pass-Throughs , Tax , Tax - Acquisitions & Restructurings
3-Apr-00	“Leverage and Taxes” - WorldTrade Executive, Inc. International Finance & Treasury Type: Articles Author(s): David R. Ryder , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2000	“New Consolidated Return OFL Regulations Sacrifice Principles to Maximize Revenue” - TAXES, The Tax Magazine Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2000	“The Limited, Inc. v. Comr.: Strategy to Use Foreign Earnings in the United States Subject to Sec. 956” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 14, 2000	“Sale of Lower-Tier CFC: IRS Advises That Branch Election Does Not Avoid Subpart F” - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Pass-Throughs , Tax , Tax - Acquisitions & Restructurings
January 2000	"Tax Efficient Cross-Border Sales and Manufacturing Structures" - IBFD Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

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Articles & Books

2008

Subpart F: The Same-Country-of-Manufacture Exception

Proposed Subpart F Contract Manufacturing Regulations

Short-Term CFC Loans May Avoid Code Sec. 956

2006

CFCs - Sections 959-965 and 1248

Look-through Treatment for Related Controlled Foreign Corporation Payments

2005

¶800 Temporary Incentive for Repatriation of Earnings Clarified

¶805 Look-through Treatment for Sales of Partnership Interests Clarified

2004

American Jobs Creation Act of 2004: Law, Explanation and Analysis

2003

“Subpart F Repatriation: Distribution Timing is Everything,”

“Subpart F Hopscotch Rule Permits Targeted Repatriation,”

“Tax Beneficial Finance Structures for Acquiring Foreign Targets,”

“Final Brown Group Regs.: Aggregate/Entity Duplicity,”

“Structures that Reduce Source Country Taxes,”

“Final Regulations Apply Subpart F to a CFC's Distributive Share of Partnership Income,”

"From Storefronts to Servers to Service Providers: Stretching the Permanent Establishment Definition to Accomodate New Business Models"

“Look-Through For 10/50 Joint Venture Corporations: Not a Panacea,”

“The Limited Case: A Refresher in Statutory Interpretation,”

2002

Final Regulations Address CFC Partner/Partnership Transactions

The Limited, Inc. v. Comr.: Appellate Court Slams Tax Court's Narrow Interpretation of §956 Bank Deposits Exception

"The Subpart F Exception for Active Financing Income"

"The Finance Company Exception to Subpart F"

"The Export Tax Incentive Is Not Dead Yet"

"All Quiet on the Subpart F Income Front"

2001

co-author, "Guidance on the Extraterritorial Income Exclusion"

"CCA 200103031: Does §338(h)(16) Apply to Deemed-Paid Credits?"

co-author, "Extraterritorial Income Exclusion: The New Export Tax Incentive"

"Planning Techniques Described in the Treasury's Subpart F Study"

"Analysis of Tax Avoidance Structures Under the Treasury's Subpart F Study"

co-author, "Seagate: Restricted Stock Gains Are Subpart F Income"

"FSA 200046008: Another Branch Attack"

2000

"Prop. Regs. Address the Application of Subpart F to a CFC's Distributive Share of Partnership Income"

“Proposed CTB Regulations Void Branch Elections: Subpart F and Other Consequences”

“Leverage and Taxes”

“New Consolidated Return OFL Regulations Sacrifice Principles to Maximize Revenue”

“The Limited, Inc. v. Comr.: Strategy to Use Foreign Earnings in the United States Subject to Sec. 956”

“Sale of Lower-Tier CFC: IRS Advises That Branch Election Does Not Avoid Subpart F”

"Tax Efficient Cross-Border Sales and Manufacturing Structures"

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