Get IRS 8926 Instructions 2018-2021
Of section 267(c) apply. In determining whether persons are related, the substance of ownership, rather than its form, controls. You determine relatedness as of the date on which an item of interest expense accrues. Consequently, changes in the relationship between the payor corporation and the payee after the accrual date are irrelevant. Partnerships. A partnership is not a related person if less than 10% of the Cat. No. 51518B profits and capital interest in the partnership are held by partn.
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