1 comments on Proposed Regulations Section 1.882 -5, relating to the interest deduction allowable to foreign corporations that do business in the United States directly, through branches or otherwise.2 While primarily of interest to foreign banks, which typi cally do
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tion 267(a) as applied in the international context, then reviews existing authorities governing what constitutes payment for purposes of Code Sec. 267(a)(3)(B).