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Description: The proper mix of debt and equity in a capital structure depends on a number of considerations, including tax. Over the years, many tax cases have considered the issue of whether particular instruments or arrangements constitute debt or equity. In recent years, as financing instruments and arrangements have become more exotic, the lines between debt and equity have become all the more blurry.
The first panel will review the history of the debt/equity issue and see how the body of case law and administrative rulings holds up to some of the more complicated financial products and arrangements in the market today. The second panel will discuss how, in practice, taxpayers make the case for their desired characterization and how the IRS attempts to refute those arguments.
| Practice Areas: | | Administrative Law & Regulation, Banking & Finance Law, Business Organizations, Business Organizations & Contracts, Tax Law | | Online Media Type: | | Video | | Production Date: | | 12/14/2011 2:00 PM EST | | Level: | | Intermediate | | Category: | | Standard | | Duration: | | 3 Hours, 30 Minutes | | Online Format: | | Live | | Course Type: | | Public |
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Purchase of this product provides online access for 180 days. If you are purchasing a live webcast, you will receive complimentary access to the on demand version for 180 days once it becomes available. Please note that the on demand and podcast versions may, or may not be accredited in your state.
If you intend to take a course for CLE credit, please make sure your state is listed in the "Accreditation" section to the upper right of the program description. Accreditation displayed is unique to the purchased program format (live conference, live webcast, on demand, podcast). Credit totals listed for live conferences are the maximum credits available. Credits issued will be based upon actual time in attendance. Credit totals for other formats are for complete programs. Partial credit is not available for any online or downloadable format.
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| • | Paul Kunkel - KPMG, LLP | • | Michael Cragg - The Brattle Group, Inc. | • | David Saltzman - Ropes & Gray, LLP | • | Alan Feld - Professor, Boston University | • | Russell Stein - Weil, Gotshal & Manges LLP | • | Miriam L. Fisher - Morgan, Lewis & Bockius LLP | • | Thomas Greenaway - KPMG, LLP | • | Bill Alexander - Associate Chief Counsel, IRS |
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