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Back-to-back financing

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Back-to-back financing
An intercompany loan channeled through a bank.
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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.
Sec. 894 final rules for recharacterizing deductible payments by Sair, Edward A. / The Tax Adviser
The proposed regulations focus exclusively on the use of back-to-back financings designed to avoid tax liability under section 881, which imposes U.
The conduit regulations: a primer by Thompson, Mitchell S. / Tax Executive
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