Our partner Yaron Reich has prepared the attached draft paper on foreign tax credit-related arbitrage transactions. While primarily focused on broad policy considerations, the paper discusses the recently proposed changes to the technical taxpayer rule in Part IV, Paragraph 3, and the new partnership FTC allocation regulation in Part VII.H.
This paper will be presented on November 10th at the University of Chicago Annual Federal Tax Conference, and will be published in the March 2007 issue of Taxes Magazine. Also attached are Powerpoint slides that Yaron will use to deliver his presentation at the Conference. Due to the length of the paper (143 pages), many of you may prefer only to print the slides.