On December 29th, 2023, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) issued Memorandum AM 2023-008 that provides guidance on the impact of Implicit support or the effect of group membership on intercompany loans and related areas, including passive association. The IRS has clarified that it is their position that it may... The post How Implicit Support Can Impact Intercompany Financing Arrangements: An IRS Transfer Pricing Perspective appeared first on Exactera.
