Page 48 - International Taxation IRS Training Guides

Inbound Financing

Example:

 Debt/equity
standards are
and
FP based on facts
developed
circumstances
Dividend income through case law.

 FP could decrease U.S. tax
liabilities through:

Preferred • Deduction of interest.

guarantee
Stock/ • Deduction of
Interest
Loan fees.
minimization
• Elimination or
of U.S. withholding tax

provide lower
U.S.1  Treaties may
or 0% withholding rates on
Interest deduction interest.

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