Proposed Internal Revenue Service regulations for multiparty, cross-border financing may constitute "a unilateral attempt by the United States to impose a tax" says Barclays de Zoete Wedd, the investment banking unit of Britain's Barclays Bank PLC.

Under the proposed regulations, the IRS will tax interest on loans from a foreign company to its U.S. subsidiary even if the loans were extended through a bank in another country which is exempt from such taxes.

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