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.
Significant tax risk to non-US companies created by America First Trade Policy
On his first day in office, President Trump signed two memoranda, the Global Tax Deal and the America First Trade Policy, covering noteworthy international...