IRS PLR: Foreign Corporation’s Income, Gain Not Connected to U.S. Trade or Business (IRC §864)

Sept. 5, 2025, 7:48 PM UTC

The IRS has published a private letter ruling on IRC §864, concluding that the income and gain earned by a foreign corporation from loan participations are not considered as effectively connected with the conduct of a trade or business within the United States. [PLR 202536015]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.

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