Because the AFRs have fallen so low, now is a good time to consider (1) making additional low-interest loans to shareholders, (2) replacing existing higher-interest shareholder loans with new ones that charge lower rates, or (3) converting demand loans
to term loans to lock in the low rates.
20) In the case of a demand loan
, the value of the interest-free repayment obligation cannot be ascertained at the time the loan is made, because the repayment date is not known in advance, nor is it pegged to predictable external events.
For demand loans
, the AFR is the short-term semiannual rate.
The borrower in the case of a demand loan
must compute and report an amount of forgone interest.
With respect to a demand loan
, the interest rate will change each year as the applicable federal rates change.
Some of the most common types of debt financing available to the entrepreneur include demand loans
, lines of credit, bridge loans, conditional sales purchases and floor financing.
Imputed interest computations for a demand loan
Under the final regulations, a demand loan
provides for sufficient interest if, in each calendar year, the interest rate, compounded annually, is no lower than the blended annual rate for the year (published in the July Internal Revenue Bulletin).
Police suspect that, in addition to the strict quota system, using impersonal means such as a telephone to demand loan
repayment facilitated the increasingly intimidating nature of the loan-collection practices, the sources said.
The $80 million revolving operating demand loan
remains in place and unchanged, with the next review scheduled for May 2016.