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NOTES 903 Tax Lawyer, Vol. 56, No. 4 NOTE THE CONTINUING BATTLE OVER FOREIGN TAX SHELTERS IN THE D.C. CIRCUIT: BOCA INVESTERINGS PARTNERSHIP V. UNITED STATES In Boca Investerings Partnership v. United States,1 the United States Court of Appeals for the District of Columbia Circuit revisted the use of foreign tax shelters by U.S. corporations. The D.C. Circuit held that losses incurred by a U.S. company through a partnership between that company and a foreign corporattion not subject to U.S. tax...

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