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Estate of Mixon

International Tax Advisory: Tax Court Flexes Its Debt-Equity Muscle on “Unrelated” Parties

August 15, 2016 By Edward Tanenbaum and Heather Ripley

A recent Tax Court case shows the government’s willingness and ability to attack financing arrangements that do not reflect arm’s-length debt standards, even without the forthcoming Section 385 regulations. Our International Tax Group analyzes that case and reviews the IRS’s decision to stop treating some FATCA intergovernmental agreements as “in effect.”

Filed Under: International Tax Advisory Tagged With: anti-earnings stripping regulations, Estate of Mixon, FATCA, FFIs, Foreign Account Tax Compliance Act, foreign financial institutions, Foreign Investment in Real Property Act, Form W-8, IGA, IGA List, intergovernmental agreements, IRS, net operating loss, NOL, Section 385, Section 881(c), Tax Court, TC Memo 2016-139, Treasury

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