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.

Date: Thursday, September 26, 2024

Time: 1:00-2:15 p.m. ET New York/Toronto; 10:00-11:15 a.m. PT Los Angeles/Vancouver

Registration:     To register for this event, go to BorderCrossings

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

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objective: Understand the treatment of intercompany loans and implicit support under the arm's-length principle and the possible legal and economic ramifications of the GLAM. This intermediate-level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

EY webcast managed and produced by Ernst & Young LLP's Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Andrea Ben-Yosef | andrea.ben-yosef@ey.com

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