Interest Netting

Interest Netting May Be Worth More Than You Think

It may be worth your while to reexamine the benefit of IRC Sec. 6621(d)’s interest netting to the amount of interest paid to and received from the IRS. Recent court decisions have expanded the meaning of “same taxpayer” by allowing interest netting between parents and their subsidiaries with different taxpayer identification numbers (TIN).   Ultimately, you […]

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