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U.S. IRS Publishes Email Response Regarding Withholding Tax Implications for Interest Paid by a Foreign Disregarded Entity of a U.S. Corporation

|Approved Changes|United States
United States

On 21 November 2014, the U.S. IRS published an email response concerning whether interest payments by a disregarded foreign entity of a U.S. domestic corporation to a foreign corporation would be considered U.S. source and subject to withholding. According to the response, because of the disregarded status of the foreign entity, interest paid by the entity is considered paid by the U.S. domesti…

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