Article
IRS Addresses ECI Implications In Cross-Border Debt Participation Arrangements (PLR 202536015)
In Private Letter Ruling 202536015 (issued June 9, 2025; released Sept. 5, 2025), the IRS addressed the U.S. federal income tax treatment of a financing structure involving a multilateral development institution (the Originator) and a wholly owned foreign special-purpose vehicle (Entity 1).
Greenberg Traurig, LLP