Alternative facts. (A) The facts are the same as in paragraph (i) of this Example 6, except as follows. Instead of owning DE1X, P owns DE3Y which, in turn, owns DE1X. In ad- dition, DE3Y, rather than DE1X, is the obli- gor on the third-party loan and therefore in- curs the interest expense on such loan. Fi- xxxxx, DE3Y on-lends the loan proceeds from the third-party loan to DE1X, and DE1X pays interest to DE3Y on such loan that is gen- erally disregarded for U.S. tax purposes.
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Samples: www.govinfo.gov, www.govinfo.gov, www.govinfo.gov
