The U.S. IRS recently published practice units on:
- Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3);
- Interest Expense Limitation Under IRC 163(j) for Controlled Foreign Corporations Post-TCJA; and
- Dividend Distribution with a Debt Issuance.
The general overviews for each practice unit include the following:
Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3)
Foreign businesses often capitalize their U.S. subsidiaries (USS) wit…