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SUMMARY: IRS chief counsel asserts that foreign corporation`s interest income from U.S. loans is taxable as effectively connected income.
TOPIC: Foreign Tax Issues
SECTION: 864. Definitions and special rules
CITATION: IRS Generic Legal Advice Memorandum (GLAM): Lending in the United States by Foreign Person Giving Rise to Effectively Connected Income, 2009ARD 183-3 (Sep. 23, 2009)
DATE: 2009-09-22
DOC TYPE: Chief Counsel Advice (CCA)
EXPLANATION:
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