Increased IRS Scrutiny of Arm’s Length Pricing of Intercompany Debt
CORPORATION TAX | 02/28/2024 Key insights Businesses must carefully evaluate loans between related companies so interest rates charged comply with the federal income tax rules. The IRS recently issued Advice Memorandum AM-2023-008, shedding light on treating intercompany interest rates in the context of group membership. Overcharging affiliates could lead to IRS scrutiny and potential adjustments. Let’s …
