04/22/2010
https://www.congress.gov...
"Why don't you do that."
"But assuming they do not eliminate--I do not disagree at all, but assuming that exception is going to remain, would it not be essential that FASB put out some guidance?"
"Thus, it appears that both courts and the IRS may seek to apply substance over form to transactions that it views as abusive."
"Of course you could lend from one to another. But that would violate Section 956."