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

On December 1, 2014   /   Corporate Tax Structure, Entrepreneurs!, International Taxation & Reporting, Tax Compliance, Tax Planning   /   Leave a comment

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

Read more →
Back to Top