Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


International PLRs of Note for the 36th week of 2014

2014-09-05

Today the IRS published the following Chief Counsel Advice relating to international taxation.

CCA 201436047 - Accrued but unpaid interest on an obligation that is U.S. property within the meaning of Code §956 is itself also U.S. property.

Tags: 956 Investments in U.S. Property, Authority - PLRs / CCAs