The 2-Minute Rule for 956 loan
In 2006, the IRS requested opinions on regardless of whether beneath this fact pattern CFC ought to be dealt with as generating a loan to USP, Consequently triggering a bit 956 inclusion. In its response to that request, the Ny State Bar Affiliation (“NYSBA”) concluded that as the subpart F routine treats a domestic partnership to be a U.S. hum