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Tax Law Roundup current law developments in U.S. taxation

Category Archives: Lending

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New IRS Guidance Expands Application of Section 956 to Controlled Foreign Corporations that Own Partnerships

Posted in International, Lending

Yesterday the IRS published two sets of regulations addressing when a US owner of a Controlled Foreign Corporation (CFC) has a deemed repatriation through the use of a CFC-owned foreign partnership. The regulations are based on Section 956, which in essence deems a repatriation to the extent a CFC invests in “U.S. property” – which… Continue Reading

IRS Treats U.S. Fund Manager as Agent of Foreign Investor – Subjecting Investor to US Trade or Business Taxation

Posted in Financial Products, International, Lending

In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund.  This conclusion is consistent with an earlier 2009 memorandum that similarly found that the activities of agents… Continue Reading