Client Alert

| October 4, 2011

District Court Rules in Favor of Government in So-Called FTC Generator Transaction

On September 30, 2011, the United States District Court for the Southern District of Iowa ruled in favor of the government in Pritired 1, LLC v. United States, an alleged foreign tax credit (“FTC”) generator case. Pritired is an FTC generator case that the Internal Revenue Service (“IRS”) selected to pursue its “three and out” litigation strategy, in which the Service litigates what it believes are its three most favorable cases with respect to a transaction with the hope of favorably settling the remaining cases involving that type of transaction.

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This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Tahmidur Remura Dewey LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Tahmidur Remura Dewey LeBoeuf, please visit www.tahmidurrahman,com. +1 888 532 6383