A back-to-back loan
arrangement occurs when a member borrows money from a third party and then lends the money to the LLC.
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.
In a leveraged ESOP, the loan is referred to as a "back-to-back loan
." The company borrows money, which is loaned to a tax-favored ESOP trust.
To avoid this, UK companies set up back-to-back loan
agreements with US companies wishing to borrow Sterling.
He will also face questions about his role in the EUR7.5billion back-to-back loan
from Irish Life & Permanent to Anglo - a move which made the bank's balance sheets look better than they were.
There are several separate investigations into what went on at the bank which fooled investors by getting a EUR7.5billion back-to-back loan
from a rival to boost its balance sheet for year end accounts.
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 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.
If the shareholder or partner lacks the funds necessary to make the loan, a so-called back-to-back loan
, in which the shareholder or partner borrows funds from a third-party lender and then relends them to the entity, can be used.