Avoiding Transfer Pricing Scrutiny On Loans To Blocker Corps

Law360 (November 5, 2018, 2:12 PM EST) -- Transfer pricing is one of the priority campaigns at the IRS Large Business and International division.

Intercompany pricing affects the tax liability in each country when a company operates in multiple countries. The tax authorities in all countries want to determine whether the transfer pricing was reasonable and consistent with an arm's-length transaction between unrelated parties. In the context of foreign investment in U.S. real estate, the IRS focal point is the financing terms between the foreign parent and the U.S. subsidiary.

Transfer Pricing Between Commonly Controlled Entities in Different Countries

Foreign investors in United States commercial real estate typically invest...

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