Now replaced by something in CTA 2009

Simon, what you need to know as most UK tax advisors don't is that in the US the dividend paid up to the checked entity will be CC income in the US probably without a tax credit so unless there are US NOLs there could be a major problem. Countless big 4 firms give bollocks advice to their US compatriates re this

Posted By: Butterworth on May 17th 2012 at 23:31:45

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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