As US advisors this provision doesn't appear to apply to us. However, if your providing advice on using Ireland as a financing strip out vehicle for European investment or using Luxembourg as a royalty strip out vehicle for European sales; then this provision could very well apply to you!
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (888 882-9243).
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