Law Office of Charles W. Cope, PLLC | European Service Company - Inbound Financing
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European Service Company - Inbound Financing


Mr. Cope developed and implemented a cross-border financing transaction involving the U.S. subsidiary of a European parent company and a related foreign subsidiary.  The structure allowed the corporate group to claim an interest deduction in the United States and in a foreign jurisdiction.  The lender qualified for U.S. treaty benefits and avoided the dual consolidated loss rules as then in effect.