An entity organized by an international organization that lends to private enterprises in developing countries doesn’t have “effectively connected” income for US tax purposes as the result of holding interests in those loans, the IRS has ruled.
An entity’s foreign-source income and gains from loan interests can be treated as effectively connected income if it’s actively conducting a banking, financing, or similar business, but “various factors taken together” support the conclusion that that’s not the case in this instance, the IRS said in a June 9 private letter ruling that was made public Friday.
Effectively connected income is connected ...