IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations

Practical U.S. /International Tax Strategies, October 2008

Douglas Stransky, Lewis Greenwald, Ameek Ashok Ponda and Eric Fuselier recently authored "IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations." The article discusses the practical implications of Notice 2008-91, which expands the ability of a controlled foreign corporation (CFC) to make short term loans to its U.S. parent to fund operations without creating an income inclusion for U.S. federal income tax purposes.