slides - NABE

Rev. Proc. 99-32 Rules Election to recognize a payable/receivable in the amount of thetransfer pricing adjustment Treated as a debt for all U.S. tax purposes Interaction with §965 Bears interest at arm’s-length rate from the time established untilsatisfied Deemed established on the last day of the taxable year for which anallocation is made If satisfied within 90 days, no additional U.S. tax consequences fromthe repatriation of cash May be treated as pre-paid if offset by bona fide debt or dividendspaid Election not available if transfer pricing penalties imposed13