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Artificial Loan Restructurings

Volume 2 No 7   |   Read Article

By Andrew P. Mitchel and Sheryl Shah

The I.R.S. has discovered that related taxpayers have been renegotiating existing intercompany loans to allow operating companies within the group to pay a higher rate of interest to a related party benefitting from favorable tax attributes without violating Code §482 principles. Andrew P. Mitchel and Sheryl Shah explain how the I.R.S. is taking aim at this new approach to self-help.  See more →