Inter-group financing by MNEs faces imminent change in the US

March 23 2017

The US tax system is on the brink of change as upcoming discussions centre on tax policy (including regulations related to inversion transactions) that will ultimately reshape the US tax treatment of inter-company financing within MNEs. In the second half of 2016, a stream of new regulations and law changes, both actual and proposed, in and outside of the US, created new issues for inter-group financing by multinationals. Stuart Chessman, director at Vivendi, discusses the salient points.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

Feature Direct Tax ITR Magazine April 2017 Europe Canada Luxembourg United States (National) North America

more across site & shared bottom lb ros

More from across our site

Direct Tax

Beyond the headlines: Why tax firms still get working parenthood wrong

Haynes and Boone’s new London partner, Alexandra Ueno-Park, argues that one-size-fits-all policies, billable-hour targets and outdated networking expectations can hold talent back

Tom Baker, September 28 2026

Podcasts

Podcast: Howden on tax insurance beyond the M&A market

Howden’s Rian Bahia explains how tax insurance can address known risks, unlock transactions and offer an alternative route through disputes and uncertainty

Tom Baker, September 28 2026

Direct Tax

A Taxing Week: Why Deloitte wins big at the ITR Awards (and your firm can too!)

Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?

Sam Sholli, September 25 2026

Podcasts

ariane calloud baker mckenzie podcast article image

Podcast: Baker McKenzie partner predicts AI audits and pillar two disputes

AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud

Tom Baker, September 24 2026

Indirect Tax

The growing market for insurance-backed receivable financing

Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims

Tom Baker, September 23 2026

Direct Tax

Milbank hires O’Melveny’s tax chair in New York

The arrival of Alex Anderson swiftly follows that of funds tax specialist Stuart Alter and suggests the Tier 3-ranked firm has higher ambitions

Tom Baker, September 22 2026

Direct Tax

WTS UK continues big four challenge with double tax hire

One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September

Sam Sholli, September 21 2026

Indirect Tax

Beyond the headlines: Inside Fieldfisher’s successful bid for EY’s trade disputes chief

Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but

Tom Baker, September 21 2026

Awards

Deloitte, KPMG, DLA Piper and Eversheds Sutherland win headline ITR Europe Awards

It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square

Sam Sholli, September 18 2026

Direct Tax

‘Difficult to read’: damning report prompts KPMG Australia to accept whistleblower failing

The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus

Sam Sholli, September 17 2026