Page 24 - International Taxation IRS Training Guides
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Example 3:

      Deferral Planning Outbound - Inv
                                                                                                           in US Prop









                                                                                Investment of


                                                                                earnings in U.S.

                                                        U.S.P
                                                                                                     Example 3
                                                                                property

                                                                                               loan to U.S.P
                                                                                CFC’s
                            $100x Loan

                                                                                is included in U.S.P’s

                                                                                income currently.
                                                         CFC




















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