Is it Debt or is it Equity? The Problem with Using Hybrid Financial Instruments
11 Pages Posted: 25 Jan 2016
Date Written: April 28, 2014
The paper discusses the debt/equity classification issues of using hybrid financial instruments under U.S. tax law and when tax treaties come into play.
Keywords: Debt and Equity, Section 385, CFC Netting rules
JEL Classification: F31, G15, K33, K34
Suggested Citation: Suggested Citation