22) The Seventh Circuit noted a possible analogy of the interest-free demand loan
of money to a revocable transfer of property, but then distinguished the two situations.
Example 3 shows how imputed interest is determined for a no-interest demand loan
made to an employee, a shareholder or as a gift.
in debt, which included the demand loan
and accrued interest
The guidelines, which were announced following endorsement by the Research Commission on the Finance and Banking Systems in the ruling Liberal Democratic Party, are designed to protect management independence because parent companies may be tempted to demand loans
from banking subsidiaries during business slumps.
Although the loan documents contained no fixed maturity dates, they were the equivalent of demand loans
(which are not uncommon in financing transactions).
The centre will consider three major types of loans - demand loans
, term loans and equity investments.
1993-24) announced the blended annual rate for 1993 demand loans
ComplianceOne will also now support numerous new transaction types, including commitment letters, oil and gas loans, commercial debt modifications, demand loans
, and evergreen loans.
It also contains examples of how below-market term and demand loans
affect corporations and shareholders.
Many owners of closely held businesses have fluctuating demand loans
to or from their businesses and accordingly use the short-term or demand-loan rate that is specified by the IRS.
as lender (the "Lender"), which amended the Demand Promissory Note (the "Demand Note") dated September 28, 2007, relating to demand loans
that may be advanced by the Lender from time to time in the principal amount of up to $3 million.
Miller apparently argued that only the interest forgone on the demand loans
, and not their principal, was a gift for Federal gift tax purposes, relying on Dickman, 465 US 330 (1984).