US Tax Issues for Foreign Acquirers of US Companies
corporation’s income before interest, tax, depreciation and amortisation. 9 6 The sale of a US real property holding corporation (the net fair market value of real property exceeds half the value of the shares) would result in effectively connected income that is taxed in the United States. IRC s 897(c). 7 IRC s 163(j). 8 IRC s 163(j)(2)(A)(ii). ................
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