The Anti-Conduit Rules - McDermott Will & Emery

The Anti-Conduit Rules


Caroline Ngo authors this article in International Tax Journal. In this article, she examines the anti-conduit regulations and related judicial doctrines that permit the Internal Revenue Service to disregard, for purposes of Code Sec. 881, the participation of intermediate entities in a “financing arrangement” where such entities are acting as “conduit entities.”