IRS issues adverse interest-netting guidance involving domestic corporation, foreign parent

Washington National Tax Services

In Chief Counsel Memorandum 201225011 (issued March 8, 2012; released June 22, 2012), IRS Chief Counsel held that interest a domestic corporation paid on a tax underpayment for Year 1 could not be used to net against interest that its foreign parent received on a tax overpayment for Year 1, because the underpayment and overpayment were not those of the "same taxpayer."

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