Rebecca Rosenberg

Ohio Northern University, Pettit College of Law

525 South Main Street

Ada, OH 45810

United States

  • Ohio Northern University, Pettit College of Law

SCHOLARLY PAPERS

6

DOWNLOADS

721

TOTAL CITATIONS

1

Scholarly Papers (6)

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1.

Codification of the Economic Substance Doctrine: Substantive Impact and Unintended Consequences

Hastings Business Law Journal, Vol. 14, Forthcoming
Number of pages: 62 Posted: 02 May 2018 Last Revised: 23 Oct 2018
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 186 (321,446)

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Federal Tax, Economic Substance Doctrine, Section 7701(o)

2.

More Generous than Accurate: The GILTI Foreign Tax Credit and Coordination of the Foreign Tax Credit Rules with the New International Tax Provisions of the TCJA

Albany Law Review, Vol. 83, 2020
Number of pages: 101 Posted: 12 Apr 2021
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 127 (441,025)

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GILTI, foreign tax credit, TCJA, 960

3.

Stars Wars: Application of the Economic Substance Doctrine to Foreign Tax Credits, and What the Future Holds

42 U. Dayton L. Rev. 165 (2018)
Number of pages: 92 Posted: 26 Apr 2018
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 117 (469,466)

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tax, Federal tax, STARS, foreign tax credits, international tax, economic substance

4.

It's All About the DRD, What's Wrong with Foreign Branches, and a Few Other Things You Should Know About the New International Tax Provisions

Loyola of Los Angeles Law Review, Vol. 53, No. 1, 2020
Number of pages: 84 Posted: 11 May 2020
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 113 (481,921)

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tax, TCJA, foreign branch, FDII, GILTI, DRD

5.

Partial Repeal of Foreign Tax Credits by the Tax Cuts and Jobs Act: Resulting Behavioral Incentives, Self-Help, and New Mechanics for Some Remaining Portions of the Credit

Number of pages: 92 Posted: 16 Oct 2018
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 107 (501,515)
Citation 1

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Tax Cuts and Jobs Act, foreign tax credits, section 902, indirect credits, international tax

6.

Codification of the Economic Substance Doctrine: Agency Response and Certain other Unforeseen Consequences

William & Mary Business Law Review, Volume 10 | Issue 1, 2018
Number of pages: 69 Posted: 13 May 2019
Rebecca Rosenberg
Ohio Northern University, Pettit College of Law
Downloads 71 (644,835)

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tax, federal income tax, 7701(o), economic substance