5 June 2015 Internal T.I. 2015-0569061I7 F - Non-interest-bearing loan to a controlled foreign affiliate -- attach -- Paragraph 17(8.1)(b)

Submitted by Anonymous (not verified) on Sun, 11/29/2015 - 02:18
debt owing to CFA parent, which had funded active business assets and was assumed on absorptive merger, qualified under s. 17(8.1)(b)