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A US citizen residing in Peru owes money to an acquaintance in Peru and has given an interest-bearing note to evidence the obligation to repay.

A US citizen residing in Peru owes money to an acquaintance in Peru and has given an interest-bearing note to evidence the obligation to repay. Is the interest on the obligation subject to w/h under sec 1441? See reg. 301-7701(b)-1(a).

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