Nothing for Something: Avoiding U.S. Withholding Obligations on Phantom Interest

 
Tax Notes International
June 6, 2011

David H. Kaplan co-authored "Nothing for Something: Avoiding U.S. Withholding Obligations on Phantom Interest" published in the June 6, 2011 edition of Tax Notes International. The article describes the circumstances under which a lender with "no reasonable expectation of collection" from an affiliated debtor does not have to accrue interest under Code Section 482.