Charles Ruchelman to Present at the Federal Bar Association Section of Taxation Program
02.25.2013
Program: Bank of New York v. Commissioner Case
Event Sponsor: Federal Bar Association, Practice and Procedure Discussion Group
The Practice and Procedure Discussion Group of the Federal Bar Association (FBA) will be holding a program on February 25, 2013, from 1:00 PM to 2:00 PM.
Caplin & Drysdale's Charles Ruchelman will be presenting on the Bank of New York v. Commissioner case. This Tax Court decision applied the economic substance doctrine to rule that the taxpayer was not entitled to foreign tax credits and other tax benefits from a foreign tax credit generator transaction. The decision is particularly noteworthy because it represents a major review and extension of Tax Court authority applying the economic substance doctrine. The discussion will summarize the ruling and discuss its potential application to future cases and transactions.
To participate in the program, please use the following dial-in information:
Dial-in number: 888-853-9376
Password: 202 861 1736
Caplin & Drysdale's Charles Ruchelman will be presenting on the Bank of New York v. Commissioner case. This Tax Court decision applied the economic substance doctrine to rule that the taxpayer was not entitled to foreign tax credits and other tax benefits from a foreign tax credit generator transaction. The decision is particularly noteworthy because it represents a major review and extension of Tax Court authority applying the economic substance doctrine. The discussion will summarize the ruling and discuss its potential application to future cases and transactions.
To participate in the program, please use the following dial-in information:
Dial-in number: 888-853-9376
Password: 202 861 1736
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