EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients.
Recent Searches
How does implicit support relate to the arm’s-length principle?
An IRS general legal advice memorandum (GLAM) on implicit support for intercompany loans (AM 2023-008) stands for a simple proposition: the interest rate on an intercompany loan should incorporate the value of any implicit support the borrower receives, as third-party lenders incorporate that value into their interest rate determinations when lending to a member of a controlled group. Whether this proposition is required under the arm’s-length principle, however, is open to debate.
This webcast will provide an overview of intercompany financial transactions, summarize the GLAM and discuss its impact on the theoretical and practical implications on intercompany lending.
We hope you will be able to join us for this important webcast.
Panelist
- John Hill, Partner, Financial Services Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP
Moderator/Panelist
- Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP
EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax.
Webcast
CPE Credits: 1.4
Time
your local time