Digital Commons Network^™

The Foreign Tax Credit War, Bret Wells

BYU Law Review

The government has been involved in a sustained war against objectionable foreign tax credit transactions. This war has caused the U.S. foreign tax credit regime to be riddled with complexity that spawns incoherent outcomes. The complexity contained in section 901 was created due to a legitimate concern: the threats posed by objectionable transactions that artificially generate excess foreign tax credits represent real policy problems. Since at least 1975, Congress and the Treasury Department have been convinced that the cross-crediting of excess foreign tax credits arising from “objectionable transactions” required a response in addition to simply relying on section 904. Thus, …

Mixed Legal Systems, East And West, Stephen Thomson

Journal of Civil Law Studies

No abstract provided.

Ryan Uresk Harvey, Rocks Off, Inc. And Wild Cat Rentals, Inc., Plaintiffs/Appellants, Vs. Ute Indian Tribe Of The Uintah And Ouray Reservation, Et Al., Defendants/Appellees., Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLEES UTE INDIAN TRIBE OF UINTAH AND OURAY RESERVATION; L.C. WELDING & CONSTRUCTION, INC.; AND HUFFMAN ENTERPRISES, INC.

South Salt Lake City, Plaintiff/Appellee, V. S. Steven Maese, Defendant/Appellant : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

Brief of Appellee

Appeal from convictions on two traffic offense infractions
in the Third Judicial District Court, Salt Lake County, the
Honorable Randall Skanchy presiding, wherein the
defendant's request for a jury trial on infraction charges
was denied.

State Of Utah, Plaintiff/Appellee, V. Jeremy Bowden, Defendant/Appellant. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

Brief of Appellee

Appeal from convictions for attempted aggravated murder, a
first degree felony; receiving a stolen vehicle and obstruction
of justice, both second degree felonies; four counts of
discharging a firearm, all third degree felonies; and failure to
stop at the command of law enforcement, a class A
misdemeanor, in the Third Judicial District, Salt Lake County,
the Honorable Douglas Hogan presiding

Kraig T. Higginson, An Individual, And Mark Burdge, An Individual, Defendants/Appellants, Vs. Jacquelynn D. Carmichael And Megan M. Moss, As Personal Representatives Of The Estate Of James E Morton, Plaintiffs/Appellees. : Brief Of Appellants, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLANTS

Appeal from the Third Judicial District Court, Salt Lake County, State of Utah
The Honorable Royal Hansen

Sam Pino, Jeanne R. Thomas, Todd Palmer, And Jodie Palmer Plaintiffs/Appellants, Vs. Entity #4812420-0140, Commonly Known As The Well Corporation, A Utah Nonprofit Corporation Defendant/Appellee. : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLANT

APPEAL FROM SUMMARY JUDGMENT
ENTERED IN THE UTAH THIRD JUDICIAL DISTRICT COURT,
SALT LAKE COUNTY, HONORABLE ROBERT FAUST

Thomas K. True And Melissa L. True, Appellants, V. Utah Department Of Transportation, Appellee. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

RESPONSE BRIEF

On appeal from a final judgment of the Second Judicial District Court,
Weber County, State of Utah, the Honorable Joseph M. Bean presiding

Conocophillips Company And Pioneer Pipe Line Company, Plaintiffs And Appellees, V. Utah Department Of Transporation And Ames Construction, Inc., Defendants And Appellants. : Brief Of Appellees, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLEES

On Appeal from the Second Judicial District Court, Davis County, State of
Utah, Honorable Thomas L. Kay, District Court No. 120700141

Richard Hardy Plaintiff And Appellant, V. Jeremy Montgomery, Julie Montgomery, Defendants And Appellees. : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

OPENING BRIEF OF APPELLANTS

APPEAL FROM THE
TRIAL FINDINGS OF FACT, CONCLUSIONS OF LAW AND JUDGMENT
THE HONORABLE JUDGE HARMOND - SEVENTH JUDICIAL DISTRICT COURT
IN AND FOR CARBON COUNTY, STATE OF UTAH

Utah State Engineer; Central Utah Water Conservancy District; Metropolitan Water District Of Salt Lake And Sandy; Provo River Water Users Association; Utah Lake Distributing; And The United States Of America, Appellees V. Evan Johnson, Appellant : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

In the matter of the general determination of all the rights to the use of water, both
surface and underground, within the drainage area of the Utah Lake and Jordan River
in Utah, Salt Lake, Davis Summit, Wasatch, Sanpete, and Juab Counties, in Utah.
Juab-Goshen Valley Division, Goshen Valley Subdivision, Area 53, Book 1

ON APPEAL FROM THE THIRD JUDICIAL DISTRICT COURT, IN AND
FOR SALT LAKE COUNTY, UTAH (HON. LAURA SCOTT)

ANSWERING BRIEF FOR THE UNITED STATES OF AMERICA

Carol H. Peterson, Trustee Of The Larry A. And Carol H. Peterson Family Trust, Uad, February 7, 2003, Plaintiff/Appellee, V. Mark A. Pierce; Julie D. Pierce, And John Does 1-5, Defendants/Appellants. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF THE APPELLEE

Appeal from the Fourth District Court, Millard County,
Judge Jennifer A. Brown

State Of Utah, Plaintiff/Appellee, V. Jeremy Bowden, Defendant/Appellant : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

Brief of Appellee

Appeal from convictions for attempted aggravated murder, a
first degree felony; receiving a stolen vehicle and obstruction
of justice, both second degree felonies; four counts of
discharging a firearm, all third degree felonies; and failure to
stop at the command of law enforcement, a class A
misdemeanor, in the Third Judicial District, Salt Lake County,
the Honorable Douglas Hogan presiding

State Of Utah, Plaintiff/Appellee, V. Cullen Christopher Carrick, Defendant/Appellant : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLANT

Appeal from Sentence, Judgment, Commitment entered on March 1, 2016, in the First
District Court, Box Elder County, the Honorable Brandon J. Maynard, presiding

ORAL ARGUMENT REQUESTED

State Of Utah, Plaintiff/Appellee, V. Cullen Christopher Carrick, Defendant/Appellant : Reply Brief, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

REPLY BRIEF OF APPELLANT

Appeal from Sentence, Judgment, Commitment entered on March 1, 2016, in the First
District Court, Box Elder County, the Honorable Brandon J. Maynard, presiding

ORAL ARGUMENT REQUESTED

Ambivalence About Parenting: An Overview For Lawyers Representing Parents In Child Welfare Proceedings, Lisa Beneventano, Colleen Manwell

City University of New York Law Review

No abstract provided.

Family Defense And The Disappearing Problem-Solving Court, Jane M. Spinak

City University of New York Law Review

No abstract provided.

Afterword, Matthew I. Fraidin

City University of New York Law Review

No abstract provided.

Phillip Grimm, Plaintiff And Appellee, V. Dxna Llc, A Delaware Limited Liability Company, Defendant And Appellant. : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF FOR APPELLANT

On appeal from a judgment of the Fifth Disctrict Court for Washington County,
The Honorable Pamela G. Heffernan

Conocophillips Company, A Delaware Corporation; And Pioneer Pipe Line Company, A Delware Corporation, Appellees/Plaintiffs, V. Utah Department Of Transportation, An Agency Of The State Of Utah; Ames Construction, Inc., A Minnesota Corporation; And Does 1-10, Appellants/Defendants. : Reply Brief, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

REPLY BRIEF OF APPELLANTS

Nature of Proceeding: Appeal

District Court Name: Second Judicial District Court, Davis County, Bountiful
Division, State of Utah

District Court Judge: Thomas L. Kay

Richard Hardy, Appellant, Vs. Jeremy Montgomery And Julie Montgomery, Appellees. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLEES JEREMY MONTGOMERY
AND JULIE MONTGOMERY

APPEAL FROM JUDGMENT ISSUED BY THE HONORABLE GEORGE M.
HARMOND, SEVENTH DISTRICT, CARBON COUNTY

Evan Johnson, Objector And Appellant. Vs. Kent L. Jones, State Engineer, State Engineer And Appellee, And Provo River Water Users Association, Metropolitan Water District Of Salt Lake & Sandy, Utah Lake Distributing Company, Central Utah Water Conservancy District, And The United States Of America, Affected Parties And Appellees. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

IN THE MATTER OF THE GENERAL
DETERMINATION OF THE RIGHTS TO
THE USE OF WATER, BOTH SURFACE
AND UNDERGROUND WITHIN THE
DRAINAGE AREA OF THE UTAH
LAKE AND JORDAN RIVER IN UTAH,
SALT LAKE, DAVIS, SUMMIT,
WASATCH, SANPETE AND JUAB
COUNTIES.

BRIEF OF APPELLEE UTAH STATE ENGINEER

Appeal from the Order Granting Motion for Summary Judgment of
Objection filed by Evan Johnson of the
Third Judicial District Court, Salt Lake County,
Honorable Laura Scott, Civil No. 360057298

National Title Agency, Llc, And William D. Rowley, Plaintiffs/Appellants, Vs. Jpmorgan Chase Bank, National Association, Defendant/Appellee. : Brief Of Appellee, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF THE APPELLEE

Appeal from the Third Judicial District Court, Salt Lake County, State of Utah
The Honorable Todd M. Shaughnessy

Yan Ross And Randi Wagner, Plaintiffs/Appellees, Vs. Global Fraud Solutions, Llc Defendant, Michael Barnett, Rule 64(E) Third Person Claimant Douglas R. Short Rule 11 Respondent/Appellant : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

APPELLANT'S BRIEF

Appeal from the Orders of the
Third Judicial District Court
Issued by the Honorable Judge Kennedy and the Honorable Judge Harris

Yan Ross And Randi Wagner, Plaintiffs/Appellees, Vs. Global Fraud Solutions, Llc Defendant, Michael Barnett, Rule 64(E) Third Person Claimant Douglas R. Short Rule 11 Respondent/Appellant : Reply Brief, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

APPELLANT'S REPLY BRIEF

Appeal from the Orders of the
Third Judicial District Court
Issued by the Honorable Judge Kennedy and the Honorable Judge Harris

The State Of Utah, Plaintiff/Appellee, V. Saul Martinez, Defendant/Appellant : Reply Brief, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

REPLY BRIEF OF APPELLANT

Appeal from a final judgment of conviction for Attempted Murder, a first
degree felony, in violation of Utah Code 76-5-203; Possession of a Dangerous
Weapon by Restricted Person, a second degree felony, in violation of Utah Code
76-10-503(2)(A); Aggravated Assault, a third degree felony, in violation of Utah
Code 76-5-103(1); and three counts of Felony Discharge of a Firearm, third
degree felonies, in violation of Utah Code 76-10-508.1, in the Third Judicial
District Court, in and for Salt Lake County, State of Utah, the Honorable Richard
McKelvie, presiding.

Appellant is incarcerated.

The State Of Utah, Plaintiff/Appellee, V. Saul Martinez, Defendant/Appellant : Brief Of Appellant, Utah Court Of Appeals

Utah Court of Appeals Briefs (2007– 2019)

BRIEF OF APPELLANT

Appeal from a final judgment for Attempted Murder, a first
degree felony, in violation of Utah Code 76-5-203; Possession of a Dangerous
Weapon by Restricted Person, a second degree felony, in violation of Utah Code
76-10-503(2)(A); Aggravated Assault, a third degree felony, in violation of Utah
Code 76-5-103(1); and three counts of Felony Discharge of a Firearm, third
degree felonies, in violation of Utah Code 76-10-508.1, in the Third Judicial
District Court, in and for Salt Lake County, State of Utah, the Honorable Richard
McKelvie, presiding.

Fire Insurance Exchange, Respondent, Vs. Robert Allen Oltmanns, Petitioner., Utah Supreme Court

Utah Supreme Court Briefs (2000–2020)

Appeal from Judgment of the Utah court of appeals 2016 UT app 55

Gordon Douglas Womack, Appellant/Petitioner V. Stacey Lee Womack Leavitt And Nicholle Womack Hendricksom, Respondents/Appellees : Brief Of Appellees, Utah Supreme Court

Utah Supreme Court Briefs (2000–2020)

Writ of Certiorari of the Utah Court of Appeal's Opinion Affirming the Eighth Judicial District, Duchesne County The Honorable Samuel P. Chiara

State Of Utah, Plaintiff/Appellee, V. Zachary Rigby, Defendant/Appellant, Utah Supreme Court

Utah Supreme Court Briefs (2000–2020)

On review from the judgment entered by the Utah Court of Appeals in State v. Rigby, 2016 UT App 42 before Judges Roth, Oreme, and Senior Judge Davis