My CPA mentioned IRC 267 and said I can't deduct certain expenses paid to my own foreign company — why?
I'm a Brazilian citizen and I own both a consulting firm in Brazil and a Delaware LLC. My Brazilian company provides back-office services to the LLC and charges a monthly fee. My CPA said IRC 267 restricts when my LLC can deduct these payments because the entities are related. She said the deduction might be 'deferred' until my Brazilian company recognizes the income. Can someone explain what IRC 267 does and how it affects payments between my own companies?
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