Is Foreign Interest on a Loan Taxable in a LLC

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Hi



A company in South Africa, wants to borrow funding from a US LLC.



I understand there needs to be a 'market related' interest rate charged on this.



Will the interest income from a foreign company be taxable in the US LLC?
 
If the LLC has kept its default disregarded tax status then the income is not taxed in the LLC, but passed on to the member.
 
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