The European Investment Stabilisation Function would be worth 30 billion euros and provide back-to-back loans
from the EU budget.
The day before Anglo Irish Bank was nationalised in January 2009, Con Horan, the regulator's then prudential director, said that the nation's banking watchdog was aware that the bank was colluding with Irish Life & Permanent, using what was called 'back-to-back loans
On September 26,2014, TEI President Mark C, Silbiger submitted a letter to the Canadian Department of Finance setting forth the Institute's recommended revisions to August 29, 2014, draft legislation that will restrict back-to-back loans
made through intermediaries.
It said the money that was withdrawn from the account rightfully belonged to UCPB as P39.7 million of the P40 million was applied to the payment of Fibico's back-to-back loans
with the bank.
Ndikumana and Boyce also explain the practice of 'round-tripping' or back-to-back loans
But if the Department knew Anglo was dressing up back-to-back loans
from other banks as deposits to mislead markets that is very different.
* Identify S corporations with basis limitation issues as soon as possible to emphasize to shareholders the importance of structuring S corporation loans as coming directly from shareholders and to minimize last-minute recharacterization of advances from related entities as back-to-back loans
Its origin can be traced to the late 1970s as a byproduct of back-to-back loans
. 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 financing arrangement would include back-to-back loans
. Therefore, under the conduit financing regulations, the Service would have the ability to disregard the existence of the Norwegian entity, if those provisions are otherwise satisfied.
S corporation shareholders have attempted to minimize this constraint and increase their loss limitations by creative characterizations of debt structures that often include variations of shareholder-level guarantees, indirect shareholder loans, or back-to-back loans
. The Service has contested successfully many of these structures because the courts have typically held that S corporation shareholder basis does not include any third-party debt.
The proposed regulations reserve as to the treatment of back-to-back loans
. However, based on the Service's published position regarding back-to-back loans
On behalf of Tax Executives Institute (TEI), I am writing to express our comments and concerns about the Government's proposals relating to treaty shopping and certain back-to-back loans
. We believe both proposals are overbroad, will interfere with legitimate commercial arrangements and transactions, and will impede investments in Canada or financing for such investments.