Layla Asali Quoted Regarding the Pricing of Intercompany Financing in Tax Notes Today

"Pricing of Intercompany Financing Must Be Arm's Length, IRS Says"
Tax Notes Today
07.24.15Layla Asali spoke at the National Association for Business Economics (NABE) Transfer Pricing Symposium in Washington, DC on the topic of intercompany financing and transfer pricing. She commented that there is no such thing as an "arm's-length capital structure" and that the initial analysis under U.S. case law is rather on whether a transaction is debt or equity, based on its characteristics. The panelists discussed the factors that the IRS considers in assessing whether an intercompany instrument is debt or equity, and addressed the application of the arm's length standard to the pricing of intercompany debt.
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