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2009

Date	Title
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
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, 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 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

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 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 / 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 Tax 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
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	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
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
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
Fall 2006	Code Sec. 954(c)(6) and the Same Country Rules for Sales and Services Income - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: 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
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
Summer 2006	Final Section 199 Regulations Support Taxpayer's Subpart F Contract Manufacturing Position - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: 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
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
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
Winter 2005	Computing the Section 965 Extraordinary Dividend - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: 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
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 M. 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
Fall 2005	Tidbits from Notice 2005-64 - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
September / October 2005	U.S. Thin Capitalization Rules - IBFD Type: Articles Author(s): Damon M. Lyon , Lowell D. Yoder Practice Areas & Industries: 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	Notice 2005-38: Code Sec. 965 (b)(3)’s Related Party Indebtedness Rule - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
April 18, 2005	Section 965: Temporary 85% DRD for CFC Dividends - Tax Management Memorandum Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
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 13, 2004	Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 P.S. 108-357 CFC Changes - Tax Management Memorandum Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
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
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
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
February 2004	Will Congress Answer the Hue and Cry? Is a CFC's Sale of a Partnership Interest Necessarily Passive Subpart F Income? - The M&A Tax Report Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Mergers & Acquisitions , Tax

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
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): David R. Ryder , 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
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
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 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
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 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
April 3, 2000	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	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

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