11/04/2009 11:17:39 AM EST
LexisNexis Tax Advisor - Federal Code: IRC Sec. 882(c) Foreign Corporations Connected With U.S. Business
In September 2009, the IRS and Treasury issued final regulations relating to the determination of a foreign corporation’s interest expense allocable under IRC Section 882(c) to effectively-connected income. In general, the final regulations modify the three-step calculation used to determine the amount of interest expense allocable under Section 882(c) to income that is effectively connected (or treated as effectively connected) with a foreign corporation's conduct of a trade or business within the U.S. The final regulations also adopt previously-issued guidance in Notice 2005-53, which addressed the conflict between Section 1.882-5 and certain U.S. income tax treaties.
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Lexis Explanation IRC Sec. 882(c)
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