" ... contains an analysis of debt and equity, including both their core differences and the sometimes blurry nature of the boundary between them. The Portfolio extensively examines: [t]he final and temporary debt-equity regulations that were issued on October 21, 2016; [t]he case-by-case multi-factor test, including its components, that has historically been applied to determine whether an instrument, or advance on open account, constitutes debt or equity for tax (and often legal) purposes; and [t]he continued viability and significance of the case-by-case multi-factor test under case law alongside the criteria of the debt-equity regulations."
Formatted Contents Note
Detailed analysis. Overview: the hazy boundaries between debt and equity The new regulatory tests under [section] 385 Applying the multi-factor test to distinguish debt and equity for legal and tax purposes The debt/equity multi-factor tax test explained Consequences of classification as debt or equity OECD and BEPS Working papers.
Digital File Characteristics
Source of Description
Description based on contents viewed on October 10, 2017; title from description page.
Available in Other Form
Print version: Handler, R. Arnold, 1940- Capitalizing a business entity. Arlington, VA : Tax Management Inc., -