IRS Chief Counsel Memo on Loan Origination by Foreign Entities

Below is a Client Alert memorandum discussing an IRS Chief Counsel Memorandum setting forth the IRS’ position regarding certain lending activities undertaken by foreign entities through an agent in the United States, as well as a copy of the IRS Chief Counsel Memorandum. The IRS Chief Counsel Memorandum suggests that the IRS will be more aggressive in challenging such activities. Please feel free to contact any of your regular contacts at the firm or any of our U.S. partners and counsel listed under Tax on this website if you have any questions.