Morgan Lewis

Earnings-Stripping Provisions of the Revenue Reconciliation Act of 1989

By Thomas P. McCorriston, Jr., Robert D. Comfort

This White paper discusses the limitation imposed by the "earnings-stripping" provisions of the Revenue Reconciliation Act of 1989 on the federal income tax deductibility of interest paid or accrued by corporate taxpayers to a related person whose U.S. tax on such interest is reduced or eliminated by a tax treaty.

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