2023-05-18
Yesterday the IRS published three new practice units titled:
The first practice unit discusses the deductibility of interest expense under Code §267(a)(3). Also see our flowchart dealing with Code §267(a)(3).
The second practice unit discusses whether intercompany debt should be respected as debt for U.S. federal income tax purposes.
The third practice unit concentrates on the Code §163(j) rules as applied to CFCs.
In addition, the IRS seems to be in the process of changing the name of these types of documents from "practice units" to "concept units".
Tags: 163(j) Limit on Business Interest, Other - IRS Practice Units, 385 Debt vs. Equity, 267(a)-3 Amts owed to rel'd fgn persons
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
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