OECD report on cross-border hybrid mismatch arrangements, UN publishes model double taxation convention

March 2012


A recent Tax Court memorandum opinion addresses whether an advance made by the taxpayer’s non-US parent to its US group constituted debt or equity and, therefore, whether the taxpayer was entitled to interest expense deductions. The Court, ruling in favor of the taxpayer, upheld the taxpayer's treatment of the advance as debt

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Bernard Moens
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