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SR Glossary: Below Market Loans

In the course of running a smaller company there comes times where the owner(s) may need to loan the company money.  What is usually lost in this whole transaction are the details:  How is it going to be repaid? When is it going to be repaid? And (just as important to the conversation) What interest rate is going to be charged?  (Definition:  these types of loans are usually called “demand loans” because they are due upon demand) 

When there is no interest on the loan or it is significantly below a “normal interest rate”, the IRS considered it a “Below Market Rate” loan.  The IRS feels that these types of loans should be similar to funds borrowed from financial institutions.  If you have a below market loan, the IRS will contend that interest should be imputed. The IRS has a method for imputing interest utilizing AFR interest rates. 

This is a very big issue with the IRS.  Rather than getting into a long discussion on the computation of AFR, it would be much easier for you to contact your accountant at ShindelRock [1] to assist you.  You also might contact us [1] before you make a loan to the company so that we can advise you on how to set the loan up to avoid some of these issues.