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Get Does The Bank Loan Exception

Ies to interest received by non-U.S. banks on cash collateral, and the issue will not be resolved until the IRS releases guidance on the subject. A singularly important question in derivatives transactions between a non-U.S. investor and a U.S. counterparty is whether the non-U.S. investor will be eligible for the portfolio interest exemption from the U.S. foreign withholding tax. The question is particularly important for investors from jurisdictions that either do not have a tax treaty with.

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