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Managing Director Stefanie Perrella and Vice Presidents Paul Koppel and Zachary Held from Duff & Phelps’ Transfer Pricing practice were recently featured in an article published by Bloomberg BNA’s Tax Management Transfer Pricing Report titled, “Evolution of Common Law Factors Characterizing Intercompany Debt.” The article explains the evolution of U.S. common law regarding debt characterization through a brief chronology and considers the common law standards in the context of recent regulatory change.
Read the full article.
Reproduced with permission from Tax Management Transfer Pricing Report, 27 Transfer Pricing Report, 6/28/18. Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com