Tax Court Addresses §956 Issues Concerning CFC Loans and Guarantees - McDermott Will & Emery

Tax Court Addresses §956 Issues Concerning CFC Loans and Guarantees

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Overview


Lowell Yoder wrote this bylined article on a recent US Tax Court case, Crestek v. Commissioner, which addressed several issues concerning the application of §956 to CFC (controlled foreign corporation) loans and guarantees. The court “applied a plain reading of the Code in determining the treatment of investments in US property held by CFCs,” Mr. Yoder wrote.