I agree with that - just not sure it could be done as simply as you first suggested

How does the Delaware LLC route work?

I didn't realise you'd get the arb clearance on something like that, strikes me as fairly and squarely within the target of the rules. You'd have to have an excellent commercial rationale for the funding method chosen I suppose.

Posted By: SimonOTBC on May 17th 2012 at 17:10:27

Message Thread

?258,909...average amount of interest paid per day by Manure over last 9 months (Other Football) - Tony Martin, May 17, 14:56:48
- It's pretty meaningless (Other Football) - Butterworth, May 17, 15:27:00
  - No they don't - avoidance involving arbitrage would deny them the deduction in the UK (n/m) (Other Football) - SimonOTBC, May 17, 16:09:48
    - No it wouldn't (Other Football) - Butterworth, May 17, 16:56:39
      - Besides what they have probably done (Other Football) - Butterworth, May 17, 17:02:28
        
        I agree with that - just not sure it could be done as simply as you first suggested (Other Football) - SimonOTBC, May 17, 17:10:27
        
        Delaware LLC (Other Football) - Butterworth, May 17, 22:50:25
        
        Now replaced by something in CTA 2009 (Other Football) - Butterworth, May 17, 23:31:45

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