The US Tax Court has held that an advance made by a foreign company to its US subsidiary is a loan and thus the US subsidiary's payments on the advance are deductible as interest for US Federal income tax purposes. NA General Partnership & Subsidiaries, Iberdrola Renewables Holdings, Inc. & Subsidiaries (Successor in Interest to NA General Partnership & Subsidiaries) v. Commissioner of Internal Revenue, T.C. Memo. 2012-172 (Docket No. 525-10, 19 June 2012).
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