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United States - CFC’s Indirect Investments in US Property Results in Income Inclusion for US Purposes

United States
P. Carman
Finance and Capital Markets (formerly Derivatives & Financial Instruments), 2014 (Volume 16), No 6
13 November 2014
An internal memorandum in the Chief Counsel’s Office of the US Internal Revenue Service (IRS) concluded that a taxpayer was not successful in limiting the amount of an income inclusion that was recognized by a US parent of an international affiliated group when a group member loaned money to the US parent. The IRS looked through the intermediate lender to the source of the funds within the controlled group to determine the appropriate amount of the income inclusion.
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