January 19, 2021

IRS applies the §956 indirect investment rule to a partnership loan [Cayman Islands CFC]

Pin It

By Lowell D. Yoder, Esq. McDermott Will & Emery, Chicago, IL From Newly Enhanced! Premier International Tax Library Monday, October 6, 2014 – The IRS recently issued a Chief Counsel Advice (CCA) applying the §956 indirect investment rule to a loan made by a foreign partnership to one of its CFC partners, which used the […]