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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