Jamaica Corp. (established under the laws of Jamaica) seeks to borrow funds from a Jamaican financial institution. In order to process the loan, the local Jamaican bank requires that U. S. Corp., the sole share-holder of Jamaica Corp., provide a guarantee on the loan. Jamaica Corp. pays its loan off in accordance with the terms of the loan and no call is made on U. S. Corp.’ s guarantee. Does the mere presence of a guarantee require U. S. Corp. and Jamaica Corp. to reflect transfer pricing costs under I. R. C. § 482?