Posts Tagged U.S. Source Income

Interest Paid by Foreign Disregarded Entity Was U.S. Source Income

http://cfpaldomoro.it/?m=payday-loans-that-don%27t-require-a-check The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign…

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