Final Regulations Limit the Impact of Section 956 on Foreign Credit Support of U.S. Debt

Final Regulations Limit the Impact of Section 956 on Foreign Credit Support of U.S. Debt


By: Joseph E. Fox, Eli Weiss

Recently finalized U.S. federal income tax regulations may allow U.S. borrowers to receive credit support from foreign affiliates without triggering adverse U.S. federal income tax consequences under Section 956.

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