Lowell Yoder wrote in this bylined article that a loan to a related US person held by a controlled foreign corporation (CFC) at the end of a quarter will not trigger an inclusion under Section 956 Subpart F if the loan is repaid within 30 days from the time it is incurred. This exception applies only if the CFC does not hold for 60 or more days during its taxable year any obligations of related U.S. persons that (regardless of the 30-day exception) would be subject to Section 956. Read the full article.
