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<a href="https://www.goldbergkohn.com/people/jonathan-m-cooper/">Jonathan Cooper</a> and <a href="https://www.goldbergkohn.com/people/stephen-j-legatzke/">Stephen Legatzke</a>, partners in the firm's Commercial Finance and Corporate groups, co-authored "Opportunity For Increased Foreign Subsidiary Report: New IRS Proposed Tax Regulation Limiting '956 Deemed Dividend' Tax Impact," published in the January/February 2019 edition of The Secured Lender.

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The article discusses Section 956 of the US Tax Code, which is often one of the main obstacles to cross-border lending. Section 956 often treats guarantees and collateral provided by foreign subsidiaries to support loans to U.S. borrowers as deemed taxable dividends. The IRS recently announced a proposed regulation that, if finalized, could substantially eliminate such obstacle and enable lenders to significantly expand their cross-border lending activities and improve their collateral positions.

With permission from The Secured Lender, the article is available to be downloaded below.

https://admin.goldbergkohn.com/wp-content/uploads/2023/09/TSL0119_Cooper-1.pdf

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Jonathan M. Cooper

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Jonathan Cooper and Stephen Legatzke Author “Opportunity for Increased Foreign Subsidiary Report: New IRS Proposed Tax Regulation Limiting ‘956 Deemed Dividend’ Tax Impact”

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