The Resource The evolution of tax-advantaged intercompany lending programs

The evolution of tax-advantaged intercompany lending programs

Label
The evolution of tax-advantaged intercompany lending programs
Title
The evolution of tax-advantaged intercompany lending programs
Creator
Subject
Language
  • eng
  • eng
Summary
The authors discuss how the new controlled foreign corporation (CFC) look-through rules can add more value to a multinational company's in-house bank. An effective intercompany lending program can produce significant tax benefits. With the new so-called CFC look-through rules part of the U.S. tax code for the next two years, the benefits of a well-run program are even greater. A best-in-class intercompany lending program can be accomplished only by using an in-house bank. This article explores how and why growing multinational corporations (MNCs) often evolve their intercompany financing strategies into full-fledged in-house banks and why the new CFC look-through rules can now add significantly more value to these structures
Citation source
In: Tax notes international. - Arlington. - Vol. 46 (2007),
http://library.link/vocab/creatorName
  • Hoffman, S.A
  • Amacher, K
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • intercompany loan
  • CFC
  • looking through
  • MNE
Label
The evolution of tax-advantaged intercompany lending programs
Instantiates
Publication
Note
Also available electronically 2007 WTD 88-6
Note
20070522
Label
The evolution of tax-advantaged intercompany lending programs
Publication
Note
Also available electronically 2007 WTD 88-6
Note
20070522

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