Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Three New IRS Practice Units - 267(a)(3), 385, and 163(j) for CFCs


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.

These new practice units have been added to our Practice Units By Topic page.

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