Treasury Finalizes Conduit Financing Regulations Under Section 881

By Jonathan Prokup On December 9th, the IRS issued final regulations under Code section 881 that treat a disregarded entity as a person to determine whether a “financing arrangement” exists for purposes of applying the conduit financing regulations.  The finalized regulations may deny tax benefits otherwise available from U.S. tax treaties when a multi-party financing … Continue reading Treasury Finalizes Conduit Financing Regulations Under Section 881

Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again

By Jonathan Prokup It seems that one of our favorite topics is back in the news: the sourcing of guarantee fees.  As reported in today’s Tax Notes, Robert Driscoll, withholding technical advisor for LMSB, was recently quoted as saying that guarantee fees might not be considered U.S.-source income if the guarantor is a qualified resident … Continue reading Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again