Boston University School of Law
Associate Tax Counsel at GoldenTree Asset Management LP
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Specialties: International and domestic tax planning and structuring for corporations, private equity funds, and hedge funds
Assist with tax planning/structuring, reviewing debt modifications, investments, workouts, and restructurings involving various global funds and accounts. Monitor and research issues relating to withholding tax, tax treaties, foreign tax mitigation, effectively connected income, FIRPTA, PFIC, CFC, market discount, OID, partnership, and corporation tax considerations.
The article provides a comprehensive analysis of the mechanics of the rules under section 304 governing redemptions through the use of related corporations within the domestic and international context. The article acknowledges the validity of the anti-abuse provisions within the domestic context, but argues for a relaxation of such provisions within the international context. In particular, the article appeals to other IRC sections (e.g., 108 regarding tax attribute reduction, 884 regarding branch profits tax, 965 regarding dividends received deduction) as models that could assist in revising the way section 304 applies within the international context.
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