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Expert Analysis

Tax Court Ruling Signals Cross-Border Loan Scrutiny

By Xenia Garofalo, Karl Zeswitz and Brian Tschosik ( March 11, 2026, 4:55 PM EDT) -- While the rules in Internal Revenue Code Sections 860H through 860L applicable to financial asset securitization investment trusts, or FASITs, were short-lived — enacted in 1996 and repealed in 2004 — a provision exempting legacy arrangements has allowed disputes regarding FASIT qualification to continue.[1]...

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