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.”
foreign financial institutions
Our International Tax Group discusses the IRS’s proposed update to the qualified intermediary agreement set to expire this year.
Click here to read the full advisory.