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Russian Recovery Fund v. U.S.

Volume 2 No 9   /   Read Article

By Stanley C. Ruchelman and Kenneth Lobo
For many tax advisers, it is fashionable to complain about the O.E.C.D.’s B.E.P.S. project because it imposes an unrealistic standard of behavior on multinational groups. Then, along comes a case such as Russian Recovery Fund, Ltd. v. U.S., and one understands the problem of real base erosion. The case involved a distressed asset/debt ("D.A.D.") transaction. Here, hubris and greed in the financial services sector team up to make the O.E.C.D. look good.  See more →