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.