On September 26,2014, TEI President Mark C, Silbiger submitted a letter to the Canadian Department of Finance setting forth the Institute's recommended revisions to August 29, 2014, draft legislation that will restrict back-to-back loans
made through intermediaries.
7 million of the P40 million was applied to the payment of Fibico's back-to-back loans
with the bank.
The OCC found these loans were similar to back-to-back loans
But if the Department knew Anglo was dressing up back-to-back loans
from other banks as deposits to mislead markets that is very different.
Identify S corporations with basis limitation issues as soon as possible to emphasize to shareholders the importance of structuring S corporation loans as coming directly from shareholders and to minimize last-minute recharacterization of advances from related entities as back-to-back loans
Very quickly these back-to-back loans
matured into what is known today as swaps.
A financing arrangement would include back-to-back loans
S corporation shareholders have attempted to minimize this constraint and increase their loss limitations by creative characterizations of debt structures that often include variations of shareholder-level guarantees, indirect shareholder loans, or back-to-back loans
As a result, many lenders prefer back-to-back loans
However, based on the Service's published position regarding back-to-back loans
On behalf of Tax Executives Institute (TEI), I am writing to express our comments and concerns about the Government's proposals relating to treaty shopping and certain back-to-back loans
Nevertheless, the IRS has successfully attacked back-to-back loans
in certain circumstances.