THE SPLIT DOLLARMINATOR!
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
The thin capitalization tax rules (the “Thin Capital Rules” or the “Rules”) were incorporated into our tax statute in 1992. Then no cases appeared in courts for almost three decades. Recently, however, a new case appeared in...more