U.S. IRS Practice Units on Interest Expense Limitations and Dividend Distributions with a Debt Issuance

The U.S. IRS recently published practice units on:

• Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3);
• Interest Expense Limitation Under IRC 163(j) for Controlled Foreign Corporations Post-TCJA; and
• Dividend Distribution with a Debt Issuance.

The general overviews for each practice unit include the following:

Interest Expense Limitation on Related Foreign Party Loans Under IRC 267(a)(3)

Foreign businesses often capitalize their U.S. subsidiaries (USS) wit…