We have cash from a sub in Canada that we would like to repatriate to the US for debt payment. We would like to avoid the FX gain if at all possible. I understand we can do this by loaning to a US sub (rathar than the US corp), however, the money would need to be paid back to Canada within 24 months. Is there any way to repatriate and avoid the FX gain permanently?
Thanks
Mike,
I'm not sure of the question here: in the initial transaction it seems like there should be no gain what so ever (it is just a loan from a sub to a parent). Depending on how you denominate that there could be a gain/loss to either party when it is settled.
Do you mean you want to transfer the funds permanently? As in a dividend? Or something else?
Cheers,
Keith
