6 Pages Posted: 30 Dec 2009
Date Written: November 16, 2009
A recent chief counsel memorandum held that U.S. - source interest income of a foreign corporation is income effectively connected with that corporation's lending business. This article evaluates the analysis of the memorandum and concludes that its position is incorrect under current law.
Keywords: effectively connected income, U.S. trade or business, lending business
JEL Classification: K34
Suggested Citation: Suggested Citation
Zhu, Jonathan and Shen, Myra Sutanto and Dick, Brett R., U.S. - Source Interest Income from a Lending Business (November 16, 2009). Tax Notes, Vol. 125, No. 7, p. 785, 2009. Available at SSRN: https://ssrn.com/abstract=1529530