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Nothing for Something: Avoiding U.S. Withholding Obligations on Phantom InterestTax Notes International, June 6, 2011Lewis J. Greenwald and 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.
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