As explained in an Office of Chief Counsel Memorandum released on 29 December 2023, the IRS may consider group membership in determining the arm's length rate of interest chargeable for intragroup loans and making a section 482 adjustment. The memorandum provides non-taxpayer-specific legal advice regarding the application of section 482 of the Internal Revenue Code in a case involving a foreign parent providing financial support to a U.S. subsidiary and the appropriate credit rating that should be used in determining the arm's length interest rate. The foreign parent provides a loan with an agreed interest rate of 10%, which reflects...