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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.
Bill Alexander - Associate Chief Counsel,
Paul Kunkel - KPMG, LLP
Professor Alan Feld - Boston
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,
Russell Stein - Weil, Gotshal & Manges LLP
Greenaway - KPMG, LLP
Please join the panelists and attendees
for a cocktail reception following the program.
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also available live via WestLegalEd Center. Click here to register.
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