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.
Commissioner, the Seventh Circuit rejected the Commissioner's position with regard to gift demand loans
. (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.
A split-dollar term loan is any loan that is not a demand loan
(e.g., a loan payable in full in 15 years).
The tax treatment of term loans (as opposed to demand loans
) is unfavorable-the employee must include a substantial portion of the loan in income immediately in some cases.
A below market loan is defined in the Internal Revenue Code as either a demand loan
or a term loan, depending on the repayment terms.
A term loan is defined as any loan which is not a demand loan
. The treatment of these loans depends on whether the loan is a "gift loan" or not.
The lender has extended the term of the Agreement to July 31, 2009 to allow the company time to complete the planned financings, although demand loan
has been reduced from CAD12.2m to CAD9.25m on June 15, 2009.
Thus, even after considering the tax effect of the interest-free demand loan
, he is still better off borrowing from CTI than from a bank.
The money had three principal components: $750,000 secured by equipment; a $2.5 million revolving-term loan secured by tanks and supply contracts; and a $750,000 demand loan
secured by inventory and accounts receivable.
7 Kyodo A parliamentary panel decided Tuesday to summon the heads of two prominent moneylending companies suspected of allowing employees to use intimidation to demand loan
repayments, panel officials said.
A demand loan
is usually a short-term loan with no set repayment schedule.