February 3, 2020
ECOVIS Global published an article by International Tax Partner Andre Benayoun, about financing considerations for foreign corporations under the Tax Cuts & Jobs Act.
ECOVIS Global
Excerpt:
Foreign corporations with U.S. operations need to take another look at their current debt structures with U.S. subsidiaries in light of the reduced U.S. federal corporate income tax rates, as well as the increased scrutiny and potential lack of interest deduction allowed in the U.S. due to the new Secs. 163(j) and 267A.