CCH Tax Day Report Accounts receivable established “for all Federal income tax purposes” pursuant to a closing agreement between a corporation and the IRS pursuant to Rev. Proc. 99-32, 1999-2 CB 296, did not create related party indebtedness under Code Sec. 965(b)(3). The corporation was a 100-percent U.S. shareholder of a controlled foreign corporation (CFC). […]
The post Accounts Receivable Did Not Constitute Related Party Debt of CFC (Analog Devices, Inc. & Subsidiaries, TC) appeared first on Tax & Accounting Blog.