Overview
Bloomberg BNA quoted Amanda Varma in an article titled “New CFC Loan Rules Seen as Too Broad, Tough on Companies.” The article, published September 14, discusses recent proposed IRS rules that would make it tougher for controlled foreign corporations (CFCs) to avoid US tax by making loans to foreign partnerships.
Under the proposed regulations, the obligation of a foreign partnership is viewed as an obligation of its partners. “As a result, if a CFC made a loan to a foreign partnership with only US partners, the loan would be treated as an investment in US property,” Ms. Varma tells Bloomberg BNA.
The full article can be read at Bloomberg BNA (subscription required).
