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CLE - Debt Versus Equity: A Fresh Look at a Classic Question

Wednesday, December 14, 2011 2:00 PM to 5:30 PM
Boston Bar Association - 16 Beacon Street, Boston, MA


This program has already taken place, but you can still catch up on what you missed!

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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. 


Panel I: History of the debt vs. equity issue

Bill Alexander - Associate Chief Counsel, IRS
Paul Kunkel - KPMG, LLP 
Professor Alan Feld - Boston University
David Saltzman - Ropes & Gray, LLP

Panel II: Development and state of the current debate around debt-equity tax issues

Miriam Fisher - Morgan, Lewis & Bockius LLP
Michael Cragg - The Brattle Group, Inc.
Russell Stein - Weil, Gotshal & Manges LLP 
Thomas Greenaway - KPMG, LLP 

Please join the panelists and attendees for a cocktail reception following the program.



  • Register online: Click "Sign me up" below.
  • Click HERE for a printable registration form.
  • WEBCAST: This seminar is also available live via WestLegalEd Center.  Click here to register.

*Tuition Assistance: If the cost of this seminar would preclude you from attending,
please contact us about tuition discounts via e-mail:


Sponsoring Section/Committee(s):




Sandra Vega


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