Sam Kaywood, partner in Alston & Bird’s Tax Group, addressed earnings and profits (E&P) in cross-border transactions.
“It’s worrisome to me,” said Kaywood in reference to the IRS possibly invoking Rev. Rul 80-239 to recharacterize a transaction to treat a controlled foreign corporation with E&P as the payer.
“It’s worrisome to me,” said Kaywood in reference to the IRS possibly invoking Rev. Rul 80-239 to recharacterize a transaction to treat a controlled foreign corporation with E&P as the payer.