Page 34 - International Taxation IRS Training Guides

Repatriation: Investment

in U.S. property

U.S.
Investment i n
Property
Example

(U.S.P)
U.S.P • U.S. Parent
corporation wholly
owns
CFC. CFC makes a loan

$100x.
$100x Dividend distribution of

a disguised
$100x Loan
Or • Loan as
repatriation
CFC

• Included in U.S.P’s current
income and subject
to U.S.
tax

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