In this EIA, Rufus Rhoades and Cynthia Brittain discuss inversions and the foreign tax credit. Specifically, they focus on the inversion where, under 26 USC § 7874(b), a U.S. corporation attempts an 80 percent or greater inversion (that is, a reorganization where 80 percent or more of the transferee foreign corporation's stock winds up in the hands of the U.S. transferor's shareholders).
Rufus v. Rhoades is the co-author of Rhoades & Langer, U.S. International Taxation and Tax Treaties, a six-volume treatise published by LexisNexis Matthew Bender. In addition to writing, Mr. Rhoades practices law with a concentration on International Tax matters and in all facets of federal and state income tax matters, including work with the Internal Revenue Service (IRS) and the California Franchise Tax Board on a number of controversial issues. Mr. Rhoades has received the Dana Latham Memorial Award for Lifetime Achievement in Taxation, which was presented by the Los Angeles County Bar Association Section on Taxation, and the Joanne Garvey Award presented by the California State Bar Section on Taxation for substantial lifetime contributions to the field of tax law.
Cynthia D. Brittain is Northern Trust Company's Trust Advisor Team Lead for the Santa Barbara Region. Prior to joining Northern Trust, Ms. Brittain served as Counsel at McKenna, Long & Aldridge, LLP in Los Angeles, CA, where she focused her practice on domestic and international estate and tax planning. Ms. Brittain received her LL.M in Taxation from The University of San Diego, and her Juris Doctor from California Western School of Law where she served on Law Review/International Law Journal.
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