Program Details

Debt Versus Equity: A Fresh Look at a Classic Question

Content Partner:  Boston Bar Association
Price: $180.00*
Member Price:  $150.00
This program is no longer available.

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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

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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.

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Total Credits: 3.25
Specialty Credits: 
Status: Reciprocal Credit Available
Expiration: N/A
Training Type: Online

West LegalEdcenter provides accreditation as described here. You may be able to self apply for credits in states not listed.

Check your state requirements and get contact information.
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
This product is designed to provide information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought.

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