Tax Court Addresses §956 Issues Concerning CFC Loans and Guarantees

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.