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The complementary business exception: An intermediate entity that is related to the financed entity is presumed not to take part in a tax avoidance plan if the financing arrangement allows the financed entity to actively engage in a business that forms a part of, or is complementary to, a substantial business actively engaged in by the intermediate entity.
The unrelated financing entity exception: A financing entity that is not related to the intermediate entity or the financed entity will be presumed not to take part in a tax avoidance plan if the intermediate entity is actively engaged in a substantial business (with certain exceptions).
A financed entity that is either a reporting corporation under Sec.
Specifically, the financed entity must attach a statement to Form 5471, Information Return of U.
These information reporting requirements apply only if a person with respect to which the financed entity is required to report under Sec.
A financed entity, or other person subject to the recordkeeping requirements of Sec.

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