The US Internal Revenue Service (IRS) has issued Notice 2008-91 announcing relief for income inclusions under the US Internal Revenue Code (IRC) with regard to earnings of controlled foreign corporations (CFCs) invested in US debt obligations. Earnings of CFCs invested in US property are generally treated as having been repatriated to the United States, with an attendant income inclusion required by IRC Section 956, which defines investments in US property to include, among other items, debt obligations of US persons. The IRS stated in prior IRS Notice 88-108 that short-term debt obligations would be exempted from IRC Section 956 provided...