What are the transfer pricing implications of cash pooling arrangements among related entities? How are intercompany insurance arrangements scrutinized for arm's length principles?

Dec 18, 2023 ... You will not receive a reply. Don't include personal information (telephone, email, SIN, financial, medical, or work details). Potential Title Issues Relating to “Pretended Sales” or Non-Arm's Length Transactions ... - “Since the proposed transaction appears to involve a buyer and seller ... Jul 8, 2022 ... The reason the IRS scrutinizes these transactions is because they are rarely “arms-length” transactions, which means that pricing is established as if the ... A T106 is an annual information return where a corporation reports its non–arm's length activities with non-residents. Non-arm's length transactions are ... Jan 23, 2025 ... Yes, mortgage lenders scrutinize non-arm's-length transactions, which may affect loan terms, property valuation, and approval due to potential ... Sep 20, 2024 ... However, the Income Tax Act deems some people NOT to be at arm's length with each other (non-arm's length). Related persons are deemed not to ... Jan 6, 2023 ... Non-arm's length transactions and arm's length transactions are real estate terms used to describe the relationship between the buyer and seller. Oct 13, 2022 ... They can apply to transfers between non arm's length persons, which include related persons as defined in the Income Tax Act. Related persons ... Jan 31, 2020 ... They didn't consider my home a comparable sale because it was an estate sale, and according to them, a non-arms length transaction. This study provides evidence that the existence of non-arm's-length transactions and of offshore financial centres increased the level of corporate cash ...