Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more
5/8/2019
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Credit Facilities ,
Creditors ,
Dividends ,
IRS ,
New Rules ,
Proposed Regulation ,
Section 956 ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
At this point, private equity firms are very conscious that debt of their U.S. acquisition vehicles or portfolio companies cannot be guaranteed by controlled foreign corporations (CFCs), nor can more than 65 percent of the...more