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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	Foreign Tax Credits - International Tax Journal Type: Articles Author(s): James A. Riedy PC 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

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
March-April 2007	A Fresh Start for a Troubled QBU - International Tax Journal Type: Articles Author(s): Caroline Hong Ngo , Katherine Stenander 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

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
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
September 2006	New Flexibility Under Final Regs. Affecting Foreign-Law Mergers and Section 367 - Journal of Taxation Type: Articles Author(s): Practice Areas & Industries: International Tax , Tax
September 2006	US Tax Shelters--Recent Developments - PLC Cross Border Quarterly Type: Articles Author(s): Holly K. Hemphill 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 2006	Final Regulations: Section 367 Does not Apply to Deemed Section 351 Exchanges in Section 304(a)(1) Transactions - Journal of International Taxation Type: Articles Author(s): Practice Areas & Industries: International Tax , Tax
July 2006	US Tax Shelters--Recent Developments - PLC Cross Border Type: Articles Author(s): Holly K. Hemphill 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): David S. Lee , Gregory G. Palmer 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
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 , Nicola Purcell 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 Lyon , Philip A. McCarty 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): David S. Lee , 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

2004

Date	Title
Winter 2004	The Invalidity of Reg.§1.903-1(a)-And a Tax-Recovery Strategy Suggested by the Analysis - Journal of Taxation of Global Transactions Type: Articles Author(s): Thomas D. Sykes Practice Areas & Industries: International Tax , Tax
January / February 2004	Cultural Savvy in a Multinational Client World - ABA's GPSolo Type: Articles Author(s): 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 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
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): Guy Madewell , 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
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 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

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
June 2001	"VAT on electronic services" - Blectronic Business Law Type: Articles Author(s): Nicola Purcell 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
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 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	“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
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