Debt-to-Equity Ratio for Portfolio Interest
Model the capitalization stack of a US C-Corp to maximize tax-free interest repatriation via the Portfolio Interest Exemption.
Tax-Free Yield Extractor
Model intercompany debt to maximize 0% withholding under the Portfolio Interest Exemption.
Exceeding standard thin-cap limits may trigger IRS recharacterization.
Debt Portion
Equity Portion
Annual Tax-Free Repatriation (0% Withholding)