The U.S. IRS recently published practice units on: Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3); Interest Expense Limitation Under IRC 163(j) for Controlled Foreign Corporations Post-TCJA; and Dividend Distribution with a Debt Issuance. The general overviews for each practice unit include the following: Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3) Foreign businesses often capitalize their U.S. subsidiaries (USS) with both equity and intercompany debt. The use of intercompany debt may allow for deductible interest expense which reduces U.S. taxable income. Such related party debt may be from a foreign parent company or...