CRA was engaged by a mid-market global investment company to conduct a loan interest rate benchmarking analysis. The analysis involved the determination of a synthetic credit rating of the borrower, and corresponding comparable bond yield analysis to benchmark the appropriate arm’s length interest rate. CRA also prepared the supporting OECD Master File and Local File compliant documentation.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...