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write off intercompany loan revenue.ie

Inderjeet Singh
asked this on Jun 12 16:54

FSTP Perspectives - PwC

Feb 8, 2012 . and their interaction with intercompany loan pricing, and, finally . increased Internal Revenue Service (IRS) audit . any write-off on the loan balance was not deductible . applied on the loan (i.e., if based on the group rating).
http://www.pwc.com/en_US/us/transfer-pricing-strategies/newsletters/fstp-perspectives/assets/pwc-financial-services-transfer-pricing-perspectives-winter-2012.pdf

1. Accounting policies - Standard Chartered Annual Report 2010

Inter-company transactions, balances and unrealised gains and losses on . ( i.e. on the basis of the Group's grading process, which considers asset type, industry, . To the extent a loan is irrecoverable, it is written off against the related . Loan syndication fees are recognised as revenue when the syndication has been .
http://annualreport.standardchartered.com/financial-statements-and-notes/notes-to-the-financial-statements/notes-1-to-5/1-accounting-policies.html

Thanks

Inder

Here is the error output:

ME Tax Handbook '11 Focus on the essentials - Deloitte
(including international intercompany loan). . long-term loan (i.e. exceeding 3   years) is not subject to withholding tax. . 70% of the non-resident company's   revenue is derived from . Taxpayers may apply for an advance ruling by   submitting a written . Tax losses can be carried forward and set off against   taxable income .
http://www.deloitte.com/assets/Dcom-Lebanon/Local%20Assets/Documents/TAX/Tax%20Handbook%202011%20FAW.pdf


2010 annual accounts - BAA
£149 million relating to the write-off of runway planning application costs and   write . In the year ended 31 December 2010, revenue from continuing   operations . for the retail offering is reflected in net retail income (i.e. gross retail   income less . due to write-offs of interest on the Company?s inter-company   loan from ADI .
http://www.baa.com/static/BAA_Airports/Downloads/PDF/BAA_Limited_2010.pdf
 

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Ryan Campbell
CloudBees Support

FAP Report - Inclusive Technology

Inclusive Technology had underlying revenue growth above. 15% that . Write off of inter-company loan. (172,393). -. 4. Provision against inter-company debtor .
http://www.inclusive.co.uk/Lib/Doc/about-us/2004accounts.pdf

June 12, 2012 17:54
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Kasper Nielsen

INTERNATIONAL TAX UPDATE - State Bar of Texas Tax Section

In August 2010 a number of revenue raisers affecting international tax were enacted that . Acquisitions are subject to the previous rule if they are covered by a written . investment in the U.S. shareholder (typically a loan), the E&P of the high-tax . U.S. source income (i.e., sourced similar to interest) and not foreign source .
http://www.texastaxsection.org/LinkClick.aspx?fileticket=lehVj5yye5s%3D&tabid=59

June 13, 2012 08:32
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Inderjeet Singh

memorandum - Internal Revenue Service

Jan 16, 2004 . or a portion of the intercompany loans made by -- to the entities should be treated as equity . disregarded entities, i.e., branches, effective ----------------- . the entity, taking into account balance sheet and off-balance sheet assets. . unauthorized disclosure of this writing may have an adverse effect on .
http://www.irs.gov/pub/irs-lafa/20040301f.pdf

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June 13, 2012 19:32
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Ben Walding
CloudBees
Ajax_loader_small Answer

Inderjeet / Kasper,

 

Previous accountant | AccountingWEB

Jul 17, 2012 . We have had to write a considerable amount of intercompany loans off as bad debt. . be made by the client, ie the company, and not her as a shareholder. . As the is the driving revenue earner the company is really only .
http://www.accountingweb.co.uk/anyanswers/question/previous-accountant

Practising Accountants Seminar

Apr 27, 2012 . Inter-company Loan to dormant company – Might be useful for CCS if . is worth exploring all options before writing off an inter-company loan, . Therefore, Liam will have to repay €26,000 to the Revenue, (i.e. €40k x13/20).
http://www.slideshare.net/omnipro/practising-accountants-seminar

 

Thanks,

Ben

June 13, 2012 21:41
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Inderjeet Singh

The Regulations Governing Intercompany ... - Steptoe & Johnson LLP

DISPOSITIONS, SPIN-OFFS, JOINT VENTURES,. FINANCINGS . attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or . transactions: (1) each accrual of interest on a loan; and (2) each payment .
http://www.steptoe.com/attachment.html/3575/Regulations_Intercompany_Transactions_Consolidated_Groups_2011.pdf

2009 September : Res Partners

Expense Reimbursements – Where the Parent books revenues and . When an intercompany loan is extended, the Parent records an asset in its books . If loan repayment becomes unlikely/improbable, a write-off may be required with the . than temporarily impaired” as evidenced by eroded local equity (i.e. fair value less .
http://res-partners.com/2009/09/

June 14, 2012 00:41
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Kasper Nielsen

SOUTH AFRICAN REVENUE SERVICE - SARS

Jan 29, 2010 . against income when inter-company loans are extinguished as a result of a . the Applicant will write off so much of the said amount, included .
http://www.sars.gov.za/Tools/Documents/DocumentDownload.asp?FileID=63239

 

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June 15, 2012 12:35
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Thiago Moreira
Hi there,

Accounting principles - Philips

However, currency differences on intercompany loans which . Revenues from long-term contracts . of which 17.8 write-off of in-process R&D (ATL). 93 .
http://www.philips.com/shared/assets/Downloadablefile/FinancialStatements_AR98-12935.pdf

Tax Briefing Issue 09

However, companies can opt instead for a fixed write-down period of 15 years at an . computer software which is used within a business (i.e. software applications for . Q.4 Will Revenue provide an advance opinion on whether a particular . is written off over 10 years in the accounts, while the annual royalty payments, .
http://www.revenue.ie/en/practitioner/tax-briefing/archive/2010/no-092010.html

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