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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 indicated that it is considering the overarching issue of whether intercompany debt should be priced solel…

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