Foreign Corporation's Loans Originated in US by its Agent are Subject to US Tax on a Net Income Basis | Practical Law

Foreign Corporation's Loans Originated in US by its Agent are Subject to US Tax on a Net Income Basis | Practical Law

An update on an IRS generic legal advice memorandum that analyzes a foreign corporation's US lending activities.

Foreign Corporation's Loans Originated in US by its Agent are Subject to US Tax on a Net Income Basis

by PLC Finance
Published on 25 Sep 2009USA (National/Federal)
An update on an IRS generic legal advice memorandum that analyzes a foreign corporation's US lending activities.