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Intercompany loan

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Intercompany loan
Loan made by one unit of a corporation to another unit of the same corporation.
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The regulations also address another area that the IRS felt was not being properly addressed in the past: intercompany loans and guarantees.
IRS takes aim at service issues in transfer pricing: two important ... by Hryck, David / Financial Executive
although the borrowing member cannot take an interest deduction, the lending member receives exempt interest income on the intercompany loan and can deduct interest paid to the third party; thus, there is no net interest expense disallowance on a consolidated basis, even though a consolidated borrowing supports the exempt investment).
Guidance on intercompany interest expense disallowance related to ... by Thornton, David A. / The Tax Adviser
In addition, reporting the highest intercompany loan balances during the year does not seem to serve any useful purpose.
TEI member responses concerning Form 5471 by Tax Executive
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