THE 2-MINUTE RULE FOR 956 LOAN

In 2006, the IRS asked for opinions on irrespective of whether less than this fact sample CFC should be dealt with as creating a loan to USP, As a result triggering a Section 956 inclusion. In its reaction to that ask for, the Ny Condition Bar Affiliation (“NYSBA”) concluded that as the subpart File routine treats a domestic partnership to be a