News & Analysis as of

Corporate Taxes Loans Controlled Foreign Corporations

BakerHostetler

IRS Issues Regulations That May Affect Borrowing Costs and Financing Terms of US Multinationals

BakerHostetler on

Recently proposed IRS regulations materially change the way stock and assets of foreign corporations that are “controlled foreign corporations” (CFCs) can be used to support debt of U.S. affiliates. ...more

Latham & Watkins LLP

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Latham & Watkins LLP on

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

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