The Resource U.S. Tax Court holds that guarantee fee is sourced to location of guarantor

U.S. Tax Court holds that guarantee fee is sourced to location of guarantor

Label
U.S. Tax Court holds that guarantee fee is sourced to location of guarantor
Title
U.S. Tax Court holds that guarantee fee is sourced to location of guarantor
Creator
Subject
Language
eng
Summary
Discussion of US Tax Court case "Container Corp." and the consequences for intra-group financing. The author concludes that it may become more common for U.S. corporations to receive guarantee fees from foreign subsidiaries as a result of the IRS's possible new position. These corporations should consider that the guarantee fee may be treated as U.S. source income under Container and should consider using back-to-back loans
Citation source
In: International tax journal. - Chicago. - Vol. 36 (2010),
http://library.link/vocab/creatorName
  • Feldgarden, R
  • Aaronson, R.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • intra-group financing
  • guarantee fee
Label
U.S. Tax Court holds that guarantee fee is sourced to location of guarantor
Instantiates
Publication
Label
U.S. Tax Court holds that guarantee fee is sourced to location of guarantor
Publication

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