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US IRS considers Section 482 regulation for implicit support in pricing intercompany loans

|Tax Alerts, National/Federal Taxation, T ...|United States
United States

  • According to an Internal Revenue Service (IRS) attorney, the IRS is considering the effects of issuing a new regulation clarifying that intercompany loan pricing must take into account implicit support.

  • This regulation could apply retroactively to all pre-existing intercompany debt or guarantees.

  • This could affect new transfer pricing arrangements as well as those already in place.

The IRS has indica…

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