Tax treaties explicitly guarantee that the credits will be allowed and a similar, but much less significant, rule in the Tax Reform Act of 1986, relating to the alternative minimum tax, was generally acknowledged as a violation of tax treaty obligations. European tax authorities and tax examiners in many other countries seek greater tax from U.S. multinationals such as Google, Facebook and Apple and their affiliates. Prior to joining the firm, Barnes was senior international tax counsel for General Electric and served as U.S. deputy international tax counsel at the U.S. Treasury.