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Back-to-Back Financing

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Back-to-back financing
An intercompany loan channeled through a bank.

Back-to-Back Financing
1. In foreign exchange, two equivalent loans issued by two companies in two countries to offset each other's currency risk. For example, suppose an American company wishes to open a European office and a European company wants to open an American office. The American company may lend the European company $1 million for start-up costs. This loan is calculated in dollars. At the same time, the European company loans the American company the equivalent of $1 million in euros to help with their start-up costs. Because both loans are made in the local currencies, neither company needs to worry about whether the exchange rate will favor them as the loans are paid back. This practice has become less common as currency swaps have become more common.

2. In international trade, see back-to-back letters of credit.


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894-1 (d)(2)(ii)(C)(2), a deductible payment made to an unrelated person may be treated as a dividend paid to an RFIH when the payment is part of a back-to-back financing arrangement, as defined in the conduit-financing regulations.
The proposed regulations focus exclusively on the use of back-to-back financings designed to avoid tax liability under section 881, which imposes U.
 
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