• IRS Says Income on Federal Reserve Collateral of Foreign Bank Must Be Allocated Between ECI and Non-ECI
  • July 17, 2013
  • Law Firm: Alston Bird LLP - Atlanta Office
  • In a recently released Technical Advice Memorandum (TAM) 201325012, the IRS said that interest earned by a foreign bank on notes pledged as collateral for access to the Federal Reserve must be allocated between effectively connected income (ECI) and non-ECI under the “Ten Percent Rule” in Regulations Section 1.864-4(c)(5)(ii)(b)(3).