U.S. Issues Final Rules on Related-Party Financing | KPMG | CA

U.S. Issues Final Rules on Related-Party Financing

U.S. Issues Final Rules on Related-Party Financing

Many Canadian multinationals will be affected by U.S. intercompany financing regulations.

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Many Canadian multinationals with U.S. operations will be affected by final and temporary U.S. regulations on intercompany financing, which the U.S. Treasury issued on October 13, 2016. While these regulations provide some welcome changes, the impact on related-party financing remains significant. The rules generally impose substantial documentation and recordkeeping requirements on intercompany loans and, in some cases, automatically treat an intercompany loan as equity for U.S. federal income tax purposes.

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