We are proud to be a sponsor at the 52nd Annual Conference of the USA Branch of the International Fiscal Association.
Hear from Economics Partners at Ryan Transfer Pricing experts at the following onsite event:
Friday, March 22, 2024 | 7:30–8:30 a.m. EDT
Speakers:
- Brian Vincent, Principal, Transfer Pricing
- David Suhler, Director, Transfer Pricing
Title: Unpacking the IRS’s Generic Legal Advice Memorandum (“GLAM”) on Financing Transactions: A Framework for Evaluating the Effects of Implicit Support and Passive Association on the Arm’s-Length Pricing of Intercompany Loans
Overview: The Internal Revenue Service (IRS) Office of Chief Counsel recently released a generic legal advice memorandum (“GLAM”), outlining the agency’s positions with respect to the consideration of group membership and potential implicit support in determining an arm’s-length rate of interest on intercompany loans. Brian Vincent and David Suhler of Economics Partners at Ryan will discuss pertinent aspects of the GLAM and the Department of Treasury’s Priority Guidance Plan on this topic, while exploring the economic rationale surrounding implicit support and passive association in the context of the Section 482 guidance on the arm’s-length pricing of intercompany loan transactions as well as relevant provisions of the OECD’s Transfer Pricing Guidance on Financial Transactions.
