Back-to-back loan

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Back-to-back loan

A loan in which two companies in separate countries borrow each other's currency for a specific time period and repay the other's currency at an agreed-upon maturity.

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The earlier decisions were very taxpayer-favorable, indicating that the Tax Court had changed its attitude on back-to-back loan restructuring between related entities.

S shareholder loan basis by Schwartzman, Randy / The Tax Adviser

Arrangements the IRS can recharacterize include debt guarantees and equity investments as well as back-to-back loans.

Conduit financing arrangements by Alek, Elizabeth / Journal of Accountancy

Moreover, the regulations establish a presumption (which can be rebutted by the taxpayer only by "clear and convincing" evidence) that the intermediate party would not have participated without the back-to-back loan from the financing entity if the financing entity also guarantees the liability of the borrower to the intermediate party.

The conduit regulations: a primer by Thompson, Mitchell S. / Tax Executive

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