Practical International Tax Implications of Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund for Non-U.S. Private Equity Funds and Their Investors
Author(s): Rufus Rhoades and Alexey Manasuev Date: December 2013
Analysis of the Meaning of “Willful” in the FBAR Context
Author(s): Rufus Rhoades and Alexey Manasuev Date: September 2013
Eschewing Obfuscation: The Creditability of Foreign Taxes and the Supreme Court
Author(s): Rufus Rhoades and Alexey Manasuev Date: December 2012
Inversion Regulations: The Illusory “Safe Harbor”
Author(s): Rufus Rhoades and Alexey Manasuev Date: September 2012
Practical Tax Considerations Relevant to U.S. Totalization Agreements
Author(s): Rufus Rhoades and Alexey Manasuev Date: June 2012
Practical Tax Considerations for Taxpayers Applying the Economic Substance Doctrine to the Act of Incorporation
Author(s): Rufus Rhoades and Alexey Manasuev Date: March 2012
Practical Tax Considerations for Sovereign Wealth Fund Investments in the United States
Author(s): Rufus Rhoades and Alexey Manasuev Date: December 2011
Practical Tax Considerations for Real Estate Investment Trusts (REITs) and Their Foreign Shareholders
Author(s): Rufus Rhoades and Alexey Manasuev Date: December 2011
Recent IRS Guidance on Life Insurance Payments in the Form of Viaticals
Author(s): Rufus Rhoades and Alexey Manasuev Date: January 2011
Procter & Gamble Co. v. U.S. and the Foreign Tax Credit Noncompulsory Payment Requirement and Competent Authority Assistance
Author(s): Rufus Rhoades and Alexey Manasuev Date: January 2011