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U.S. Tax Concerns Facing Foreign Lenders  


Author:  Peter A. Glicklich.; Heath Martin.


Source: Volume 29, Number 03, January/February 2016 , pp.45-48(4)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

Foreign lenders may become subject to U.S. federal income tax if they make loans to borrowers in the United States. The authors discuss recent guidance from the IRS, providing insight regarding the kinds of lending activities that are considered a taxable business in the United States when conducted by foreign investment funds.

Keywords: effectively connected income, U.S. trade or business, international tax, U.S. tax, debt funds, CCA 201501013

Affiliations:  1: Davies Ward Phillips & Vineberg LLP; 2: Davies Ward Phillips & Vineberg LLP.

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