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. domestic corporation and therefore subject to withholding. The full response can be found on the IRS website.