H. Jacob Lager

Posts Tagged ‘1446’

Recent Rulings – PLRs

In Uncategorized on January 14, 2012 at 1:24 am

PLR 201202001 Release Date: 1/13/2012

Payments to foreign bankruptcy creditors on non-subordinated notes are treated as payments on the notes, subject to Section 1446 withholding to the extent these payments are attributable to interest.

http://www.irs.gov/pub/irs-wd/1202001.pdf