IRS Applies the §956 Indirect Investment Rule to a Partnership Loan

Lowell Yoder wrote this bylined article on a recent IRS Chief Counsel Advice (CCA) applying the §956 indirect investment rule to a loan made by a foreign partnership to one of its CFC partners, which used the funds to invest in U.S. property. The CCA’s “conclusion is inconsistent with the fundamental rule of treating partnerships as entities and case law that consistently applies the entity approach to Subpart F determinations,” Mr. Yoder wrote. Read the full article