Tax Relief for U.S. Parents Receiving Credit Support from Foreign Sub - Hogan Lovells Engage
Description
Tax structuring under the previous regimePrior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax purposes, a dividend was deemed created when a U.S. borrower pledged, as security for its
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