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United States - Pricing of a Guarantee Fee in a Related-Party Context

United States
J.A. Riedy; N. Anwar; D.R. Wright
International Transfer Pricing Journal, 2010 (Volume 17), No 4
16 June 2010
In a recent case, Container Corporation v. Commissioner, the US Tax Court addressed the question of the source of a loan guarantee fee paid by a domestic corporation to a foreign parent corporation for purposes of determining whether there is a US withholding tax obligation. The case provides a good vehicle for the discussion of the transfer pricing aspects of guarantee fees.
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