McDermott - Publications

Articles & Books

Filter By:
Or:

2011

Date	Title
October 31, 2011	IRS Memorandum Offers Taxpayer Benefits Relating to Conversions of Insolvent Foreign Corporations Into Partnerships - Practical International Tax Strategies Type: Articles Author(s): Michael J. Wilder Practice Areas & Industries: International Tax , Tax
October 2011	Blog Contributor on Forbes.com - Forbes.com Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 17, 2011	U.S. Federal Income Tax Issues Arising From a Partial Disintegration of the Eurozone - Tax Analysts Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
October 11, 2011	Tax Savings Through Foreign Procurement - Forbes.com Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: International , International Tax , Tax
October 10, 2011	Financing Foreign Subsidiaries of U.S. Multinationals - Tax Management International Journal Type: Articles Author(s): Robert H. Dilworth , Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
October 2011	Swap Assignments Safe Harbor Extended in Anticipation of Dodd-Frank Implementation - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: International Tax , Tax
May 30, 2011	Section 338 Elections in the Age of Covered Asset Acquisitions - Tax Notes Type: Articles Author(s): Robert A. Clary II , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2010

Date	Title
December 1, 2010	So Last Century! - Spear's Magazine Type: Articles Author(s): Martyn Gowar Practice Areas & Industries: International Tax , London , Tax , Tax - London
August/September 2010	Foreign Employment Income in the Italian Tax Setting - IBFD Bulletin for International Taxation Type: Articles Author(s): Alessio Persiani Practice Areas & Industries: International Tax , Tax , Tax - Italy
March 2010	UK Corporate Tax Update - Journal of International Taxation Type: Articles Author(s): James Ross Practice Areas & Industries: International Tax , Tax
September-October 2010	Transfer Pricing and Dispute Resolution—The U.K. Experience - International Tax Journal Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International Tax , London , Tax , Tax - London , Transfer Pricing
July 2010	New Protocol to Barbados-China Double Tax Agreement Enters into Force - Practical International Tax Strategies Type: Articles Author(s): Thomas W. Giegerich Practice Areas & Industries: International Tax , Tax
July 23, 2010	'Beginning Of Construction' Guidance For 1603 Grants - Law360 Type: Articles Author(s): Caroline Hong Ngo , Martha Groves Pugh , Philip Tingle Practice Areas & Industries: International Tax , Tax
July 20, 2010	Negotiating Over-the-Counter Derivative Contracts - Westlaw Business Currents Type: Articles Author(s): Andrea S. Kramer - Alton B. Harris Practice Areas & Industries: Financial Products, Trading & Derivatives , International Tax , Structured Finance and Derivatives , Tax
July 2010	CFCs--General Overview, 926-3rd T.M. - BNA Tax Management Foreign Income Portfolios Type: Books Author(s): Damon M. Lyon , David G. Noren , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 3, 2010	Transfer Pricing Discussion Group's Comments on IRS Schedule UTP - Tax Management Transfer Pricing Report - BNA Type: Articles Author(s): Steven P. Hannes Practice Areas & Industries: International Tax , Tax , Transfer Pricing
Spring 2010	Worthless Stock Losses from Liquidations and Related Issues in Consolidation - The Tax Executive Type: Articles Author(s): Andrew Blair-Stanek , Matthew K. White , Michael J. Wilder Practice Areas & Industries: International Tax , Tax
February 12, 2010	Notice 2008-91 Exception to §956: Guidance on Particular Issues - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2009

Date	Title
October 9, 2009	Subpart F: "Indicia of Manufacturing" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September / October 2009	The Reclassification of DEs as CFCs Under Obama's CTB Proposal Can Result in Subpart F Income - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 14, 2009	Obama Administration's Proposal to Limit Classification of Foreign Entities as Disregarded is Misguided - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July 15, 2009	Compaq: Find Another Poster Child. The Business Purpose Doctrine is Alive and Well in the Fifth Circuit - International Tax Journal Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
June - July 2009	Tax-Efficient Business Practices in the Face of Unprecedented International Tax Enforcement - Bank Accounting & Finance Type: Articles Author(s): Matthew Boch , Gregory G. Palmer - This article is reprinted with the publisher's permission from BANK ACCOUNTING & FINANCE, a bi-monthly journal published by CCH INCORPORATED. Copying or distribution without the publisher's permission is prohibited. To subscribe to BANK ACCOUNTING & FINANCE or other CCH Journals please call 800-449-8114 or visit www.tax.cchgroup.com. All views expressed in the articles and columns are those of the author and not necessarily those of CCH INCORPORATED or any other person. Practice Areas & Industries: International Tax , Tax , Tax Controversy
July / August 2009	Obama Administration's International Tax Proposals - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 12, 2009	Limits on the Application of the Subpart F Branch Rules - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May / June 2009	New Code Sec. 367(a) Regulations Apply to International Code Sec. 304(a)(1) Transactions - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 10, 2010	New Temporary Regulations Fundamentally Alter Operation of §304 and the Application of §1248 - Tax Management International Journal Type: Articles Author(s): Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
April 10, 2009	Same-Country-of-Manufacture Exception to Subpart F Sales Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 30, 2009	The Proposed New U.K. Worldwide Debt Cap - Tax Notes International Type: Articles Author(s): James Ross Practice Areas & Industries: International Tax , Tax , Tax - London
March 13, 2009	Improving Efficiency of Global Cash Utilization Accelerated Payments for Inventory - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March / April 2009	Final and Temporary Subpart F Contract Manufacturing Regulations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 9, 2009	Gleanings from §956 Developments - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January / February 2009	Notice 2008-91 Expands Code Sec. 956 Exception for Short Term Obligations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January/February 2009	Tax Reform: International Tax Issues and Some Proposals - International Tax Journal Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax

2008

Date	Title
November / December 2008	The Subpart F Physical Manufacturing Exception - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 10, 2008	Foreign Subsidiary's Acquisition of a Foreign Target with U.S. Parent Stock - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September / October 2008	Proposed Regs Address Application of Subpart F Branch Rule Where All Acitivites Are Conducted in a Branch - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 8, 2008	Subpart F: The Proposed Non-Physical Manufacturing Branch - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
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
June 26, 2008	The Foundation of International Tax Reform: Worldwide, Territorial and Something in Between - Statement to the Senate Finance Committee Type: Other Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
June 13, 2008	Subpart F Manufacturing Exception: Proposed Non-Physical Definition of Manufacturing - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 2008 / June 2008	Foreign Tax Credits - International Tax Journal Type: Articles Author(s): James A. Riedy PC Practice Areas & Industries: International Tax , Tax
May / June 2008	Proposed Subpart F Contract Manufacturing Regulations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 11, 2008	2007 Technical Corrections to Sec. 954(c)(6) - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March / April 2008	CFC Purchase of Stock in a Related CFC: Code Sec. 304 vs. D Reorganization Treatment - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 8, 2008	Cash D Reorganizations—Selected International Issues - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January / February 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

2007

Date	Title
2007	Business Operations in Germany - Tax Management - BNA Tax Management Type: Books Author(s): Dirk Pohl Practice Areas & Industries: International Tax , Tax , Tax - Germany
November / December 2007	Gain Derived by a CFC from the Sale of a Business - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 28, 2007	IRS Applies Section 956 Thirty-Day Exception to Quarters - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 13, 2007	A Bird’s Eye View of §367’s Application to Triangular Reorganizations Involving CFCs - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September / October 2007	Notice 2007-48: IRS Takes a Shot at Public Triangular Reorganizations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 10, 2007	Application of Subpart F to Gain Derived by a CFC from the Sale of a Business: Form Matters - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July / August 2007	International Planning Using Code Sec. 304(a)(1) - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 8, 2007	Practical Applications of the CFC Look-Thru Rule Under Notice 2007-9 - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 11, 2007	Notice 2007-13: New Subpart F Substantial Assistance Rule - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May / June 2007	Code Sec. 338(g) Election Applied to Foreign Targets: Permissible Tax Arbitrage - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March-April 2007	A Fresh Start for a Troubled QBU - International Tax Journal Type: Articles Author(s): Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
March 5, 2007	constructive dividends and hidden deposits according to German Annual Tax Act 2007 - formally and materially correspondence - FR - Finanz-Rundschau Type: Articles Author(s): Dirk Pohl , Arndt Raupach Practice Areas & Industries: International Tax , Tax
March / April 2007	Updating the Subpart F Rules for Active Income - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 9, 2007	Adjustments to Stock Basis in Lower-Tier CFCs - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2006

Date	Title
12/8/06	Final §367(b) Attribute Regulations-Highlights and Planning Considerations - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
December 8, 2006	PTI Sharing Under the Proposed §959 Regulations - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2006	Intangible Property Used Outside the U.S.: Active vs. Passive Treatment of Royalties and Gain - JTGT Type: Articles Author(s): Damon M. Lyon , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2006	President's Advisory Panel Recommendations Concerning Taxation of Foreign Income - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
November 2006	Commission Cites Spain's Capital Gains Tax - Practical European Tax Strategies Type: Articles Author(s): Andrea L. Hamilton Practice Areas & Industries: International Tax , Tax
October 13, 2006	Technical Corrections in House Bill to the §954(c)(6) Look-Thru Exception - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 11, 2006	New Subpart F Related CFC Look-Thru Exception - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2006	US Branch Report on the Attribution of Profits to Permanent Establishments - Cahiers de Droit Fiscal International of the International Fiscal Association Type: Articles Author(s): Steven P. Hannes Practice Areas & Industries: International Tax , Tax
July 14, 2006	Subpart F: LMSB Provides Guidance Concerning the Definition of Manufacturing - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 2, 2006	Tax consequences of the migration of companies: a practitioner's perspective - EBOR (European Business Organization Law Review) Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax
May 12, 2006	Final §367 Regulations - A Fine-Tuned Version of the Proposed Regulations - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
March/April 2006	Proposed Regulatory Guidance Issued for Domestic Production Activities Deduction - International Transfer Pricing Journal Type: Articles Author(s): Gregory G. Palmer Practice Areas & Industries: International Tax , Tax
April 14, 2006	Contract Manufacturing Under Section 199: Implications for Subpart F - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2006	CFC Loans to Foreign Partnerships Owned by U.S. Shareholders - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 10, 2006	The Incongruent Definitions of Active Royalties for Subpart F and Foreign Tax Credit Purposes - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2006	New Asset Basis Adjustment Rules in Foreign Planning—Another Compliance Burden - Journal of Taxation of Global Transactions Type: Articles Author(s): James A. Riedy PC Practice Areas & Industries: International Tax , Tax
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	Financing International Operations of U.S. Multinationals - PLI/Tax Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings 2006 Type: Articles Author(s): Robert H. Dilworth 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
December 9, 2005	Notice 2005-64: §965 Qualifying Cash Dividends & Tax Computations - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
November 11, 2005	Final & Prop. Regs. §1.951-1(e): U.S. Shareholders’ Pro Rata Share of Subpart F Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 14, 2005	2005 TTCA: Amendments to §965 - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2005	Dual Consolidated Loss Regulations—The Over-Under Bet and Selected Other Issues - Journal of Taxation of Global Transactions Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
2005	United Kingdom - European Taxation Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International Tax , Tax
September 9, 2005	New Proposed Guidance on the Interaction of §§304 and 367--Issues and Unanswered Questions - Tax Management International Journal Type: Articles Author(s): Damon M. Lyon , Philip A. McCarty Practice Areas & Industries: International Tax , Tax
August 12, 2005	Notice 2005-38: Applying §965 to Mergers and Acquisitions - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Mergers & Acquisitions , Tax
July 8, 2005	Prop. Regs. §1.367(b)-4: Triangular Reorganization Rules Fixed - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2005	The Buy-In Requirement for Cost Sharing Arrangements - Journal of Taxation of Global Transactions Type: Articles Author(s): Paul Dau Practice Areas & Industries: International Tax , Tax
June 15, 2005	The Marks & Spencer case - group taxation under review by the European Court of Justice - NZG Neue Zeitschrift für Gesellschaftsrecht Type: Articles Author(s): Dirk Pohl , Arndt Raupach Practice Areas & Industries: Germany , International Tax , Tax , Tax - Germany
May/June 2005	Federal Income Tax Benefit for Domestic Production Activities - International Transfer Pricing Journal Type: Articles Author(s): Gregory G. Palmer Practice Areas & Industries: International Tax , Tax , Transfer Pricing
2005	Group Finance Companies in International Tax Law with a supplementary analysis of Dublin-Docks-companies of German parent companies - Otto-Schmidt-Verlag Type: Books Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax , Tax - Germany
April 8, 2005	Notice 2005-10: Section 965 Cash Dividends and U.S. Investments - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2005	International Taxation: Re-Thinking Check-the-Box - TAXES: The Tax Magazine Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2005	JCT Recommends Classifying Foreign Disregarded Entities as CFCs: A Time Warped Idea - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 11, 2005	Section 965: Technical Corrections Bill - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax

2004

Date	Title
December 10, 2004	Classification and Residence of Dually Chartered Entities - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2004	CFC Target: To Make or Not to Make a Code Sec. 338 Election - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
November 12, 2004	Prop. Regs.§1.951-1(e): Pro Rata Share of Subpart F Amounts Taxable to U.S. Shareholder - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder - Greg Walker Practice Areas & Industries: International Tax , Tax
October 8, 2004	Rev. Rul. 2004-77: The Classification of Single-Member Business Law - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2004	Subpart F Related CFC Look-Through Exception Provided in Tax Bills Passed by Senate and House - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 13, 2004	Pre-Sale Branch Election for CFC Target: Dover v. Comr. Says No Subpart F Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 11, 2004	Selling CFC Stock with a §338 Election: §1248 and Foreign Tax Credit Consequences - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2004	Senate Passes Tax Bill Without Contract Manufacturing Provision - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 9, 2004	Selling CFC Stock: Subpart F, Distributions and Calculating the §1248 Deemed Dividend - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2004	Tax Court Applies Penalties to Routine Foreign Tax Credit Planning Transaction - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 13, 2004	Sales and Services Income: Will There Ever Be Subpart F Legislative Reform? - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2004	Financing of medium seized businesses in the shadow of the new German thin-capitalization rules (Para. 8a Corporation tax act) - Anwaltspraxis Wirtschaftsrecht Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax , Tax - Germany

2003

Date	Title
December 12, 2003	CFC Sale of an Interest in a Partnership: A Legislative Fix Is Imperative - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
December 11-12, 2003	Application of Tax Shelter Rules to International Transactions - George Washington University/IRS 16th Annual Institute on Current Issues in International Taxation Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
October 10, 2003	Check-and-Sell Transactions: Proposed Regulations Withdrawn, But Still Under Attack - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder - Sheri L. Everson Practice Areas & Industries: International Tax , Tax
October 10, 2003	Foreign-to-Foreign Liquidations No Longer Subject to §367 Anti-Abuse Rule - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2003	Proposed Check-and-Sell Regulations Withdrawn - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2003	Tax Beneficial Structures for Acquiring European Targets - European CEO Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
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
July 7, 2003	“Worldwide Apportionment of Interest Revisited,” - Tax Notes International Type: Articles Author(s): Steven P. Hannes , James A. Riedy PC 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
May 31, 2003	"UK Tax Relief for R&D" - Practice US/International Tax Strategies Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International , International Tax , London , Tax , Tax - London
May 12, 2003	“Achieving Transfer Pricing Objectives Without Creating a U.S. Business for a Foreign Person” - Tax Notesi> Type: Articles Author(s): Steven P. Hannes 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
Spring 2003	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 2002	co-author, "Host Country Tax Consequences of Engaging in a Sale-Repurchase Transaction Using Host Country Securities" - Tax Management International Forum Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International , International Tax , London , Tax , Tax - London
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
Spring 2002	"Taking Commodities Trading Offshore: The Subpart F Conundrum" - Taxation of Global Transactions Type: Articles Author(s): Sandra P. McGill , William R. Pomierski 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
2002	Branch Reporters - International Fiscal Association 2002 Oslo Congress Type: Articles Author(s): Lowell D. Yoder - William P. Streng 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 9, 2001	“Taxing Foreign Currency Hedges” - International Finance & Treasury Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Financial Products, Trading & Derivatives , 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
July 2000	Phone commentary on the "Ireland-decision" at the highest German Tax Court as of January 19th, 2000 (I R 94/97) - Neue Juristische Wochenschrift-Cassetten, Rechtsprechung Type: Other Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax , Tax - Germany
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
April 3, 2000	Leverage and Taxes - WorldTrade Executive, Inc. International Finance & Treasury Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 6, 2000	Zero Withholding on Direct Dividends: Policy Arguments for a New U.S. Treaty Model - Tax Notes International Type: Articles Author(s): Robert H. Dilworth 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
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
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
January 2000	co-author - U.S. Transfer Pricing Rules in Tax Treatment of Transfer Pricing* - International Bureau of Fiscal Documentation* Type: Articles Author(s): Michael F. Kelleher Practice Areas & Industries: International Tax , Tax , Transfer Pricing

Print this page
E-mail this page

To (e-mail):
From (e-mail):
Message: