Do interest limitation rules apply to a foreign-owned single-member LLC with intercompany loans?
My foreign company lent money to my U.S. LLC to fund operations. The LLC pays interest back to my foreign company. Does the Section 163(j) interest limitation apply to a disregarded entity LLC? If so, how does it work when the LLC doesn't file its own corporate return? Also, does the interest I pay to my foreign company create a withholding tax obligation?
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