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can a controlled foreign corporation make a business loan to

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can a controlled foreign corporation make a business loan to a domestic (USA) real estate llc without tax implication?

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Yes, it can make such a loan provided the "loan" is truly a loan - it must have repayment provisions, and include interest in the payment calculations. Collateral will also help support that this is a real loan.

This loan must be properly disclosed by the US entity in its tax returns but there is no tax involved beyond the US entity's ability to deduct the interest expense.

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