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Internal Revenue Service › Foreign Investment Fund

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Cadwalader, Wickersham & Taft LLP

Crossing the U.S. Trade or Business Line

Cadwalader, Wickersham & Taft LLP on

YA Global Investments, LP (“YA Global”), a foreign investment fund that provided funding to portfolio companies in exchange for stock, convertible debentures, promissory notes and warrants, engaged U.S.-based Yorkville...more

Goulston & Storrs PC

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

Goulston & Storrs PC on

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...more

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