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On behalf of Tax Executives Institute (TEI), I am writing to express our comments and concerns about the revised proposals relating to back-to-back loan arrangements through intermediaries (hereinafter "the Proposals").
Roman Abramovich's policy of signing new players every season - instead of promoting any junior level players - has seen highly rated youth products, such as Josh McEachran and Jeffrey Bruma, going away on back-to-back loan spells, despite proving themselves at Stamford Bridge.
To avoid this, UK companies set up back-to-back loan agreements with US companies wishing to borrow Sterling.
5billion back-to-back loan from Irish Life & Permanent to Anglo - a move which made the bank's balance sheets look better than they were.
5billion back-to-back loan from a rival to boost its balance sheet for year end accounts.
A back-to-back loan involves two companies, each in different countries, borrowing money from local banks and then loaning money to each other.
A back-to-back loan arrangement using a hybrid entity may lower the effective foreign corporate income tax burden.
The courts and the Service have allowed shareholder debt basis for back-to-back loan and loan substitution transactions that result in indebtedness of the S corporation to the shareholder.
The back-to-back loan is very similar to the leveraged ESOP loan.
We believe that the diversity, professional training, and global viewpoint of our members enable us to bring a balanced and practical perspective to the issues raised by the treaty shopping and back-to-back loan proposals.
A Florida limited liability company (the company) wishes to borrow money (the loan) from a foreign Country X corporation (the mirror lender), which loan essentially is a back-to-back loan because another foreign Country X corporation is the originating lender (the originating lender).
A number of courts have approved back-to-back loan arrangements where the loans are valid debt and the shareholder documents them appropriately and makes payments in a manner that is consistent with the loan documents.