IRS Extends Tax Relief Through 2010 for CFC Loans to U.S. Operations

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IRS extends, until the end of 2010, relief giving controlled foreign corporations a longer window to lend money to their U.S. operations tax-free under tax code Section 956. Under Notice 2010-12, IRS also extends beneficial treatment for marketable securities. Practitioners generally welcome the IRS action; Phil West, of Steptoe & Johnson LLP, deems it “a nice Christmas present for multinationals.” The notice extends the benefit originally offered as a response to the economic crisis in October 2008: in Notice 2008-91, IRS doubled the window in which U.S. multinationals could lend money to their U.S. subsidiaries without paying tax, from 30 to 60 days.