Taxation of Debt Instruments: OID and AHYDO Rules, Distressed Debt, Contingent Capital
Navigating Latest IRS Rules and Overcoming Complexities in Structuring Capital Arrangements
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE course will prepare tax counsel to structure complicated debt arrangements. Our experienced panel will provide best practices in handling original issue discount​ (OID), distressed debt and contingent capital.
Outline
- OID Latest Developments
- Discussion of Basic Rules
- Issue Price determinations under publicly traded debt rules
- AHYDO considerations
- Distressed Debt Considerations
- Significant Modifications and Deemed Exchanges
- Cancellation of indebtedness considerations
- Capital Markets Update
- Debt-equity considerations
- Contingent convertibles and other offerings
Benefits
The panel will review these and other key questions:
- What are the key developments involving debt to include convertible bonds and distressed debt?
- What considerations should be made in the debt vs. equity characterization?
- What are the latest developments involving OID rules?
Faculty
Yoram Keinan
Partner and Chair, Tax Department
Carter Ledyard & Milburn
Mr. Keinan has over fifteen years of experience in tax law both in the United States and Israel. He focuses on U.S. and... | Read More
Mr. Keinan has over fifteen years of experience in tax law both in the United States and Israel. He focuses on U.S. and international taxation of financial products and institutions and represents major banks and investment firms. Prior to joining Carter Ledyard & Milburn LLP, he served as a shareholder at Greenberg Traurig’s Tax Department in New York.
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Mark H. Leeds
Partner
Mayer Brown
Mr. Leeds focuses his practice on the tax consequences of a variety of capital markets products and strategies. He... | Read More
Mr. Leeds focuses his practice on the tax consequences of a variety of capital markets products and strategies. He advises on the tax aspects of capital markets, structured finance, derivatives, financial products and insurance transactions and has extensive experience working with both buyers and sellers to develop and structure complex derivatives. A significant portion of his work involves the taxation of financial products and trading strategies engaged in by banks and other financial market participants.
CloseWilliam R. Pomierski
Partner
McDermott Will & Emery
Mr. Pomierski focuses his practice on the taxation of financial products and capital markets transactions, as well as... | Read More
Mr. Pomierski focuses his practice on the taxation of financial products and capital markets transactions, as well as on executive compensation matters. He advises clients on the federal income tax implications of a variety of domestic, cross-border, and global financial products and related transactions. He has worked extensively with both public and private companies, hedge funds, trading firms, financial institutions, high net worth individuals, trust advisors and family offices, in connection with a range of capital market and financial product issues.
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