Corporate finance vehicles: debt related issues
Article Abstract:
Four issues involving corporate debt include Disney's aborted zero-coupons, Rhone-Poulenc buying Rorer and using contingent value rights (CVRs), News America Holdings' zero coupons and troubled debt restructuring. Disney's question concerns debt versus equity interest in disguise. Rhone Poulenc's question concerns debt versus put options on cash settlements. News America's bonds will be taxable when redeemed because they can redeem other securities. As for troubled restructuring, the difference between tax treatment and financial accounting is explored.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
Deferring gains on corporate investments through the use of redemptions
Article Abstract:
Corporations may realize a tax advantage by redeeming stock shares instead of selling them. Redemption would involve the issuing company such that most of the stock would be redeemed while capital gains tax gets deferred. Retention of interest could negate capital gains for redemptions under section 1059. Redemption could also negate the sale or exchange provisions of section 302 if it equaled a dividend or would be proportionate.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
Proposed cross-border securities lending rules leave unanswered questions
Article Abstract:
IRS proposed rules for taxation of international securities lending are inadequate. The rules come under sections 1441, 894, 881, 871 and 861 although they address transactions similar to or defined by section 1058. No recognition of a gain or loss occurs under section 1058 when generally identical values are returned. Problems occur with substitute payments, tax treaties, fees and foreign tax credits in the proposed regulations.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: The real insiders; SEC may take securities trading issue to Supreme Court. Nobody's child: the way Americans go about caring for abused and neglected kids is a mess; the only way to fix a system that fails everyone may be for juvenile court judges and lawyers to take charge
- Abstracts: Definition of a Resident Alien - Proposed Legislative Changes. Trends: Switzerland
- Abstracts: Corporate legal structure, salary. General counsel cash compensation. Women get lower pay in law departments
- Abstracts: ERISA does not preempt state malpractice claim. Employer not liable for ERISA s. 502(c)(1) penalties for failing to provide notification of COBRA qualification event
- Abstracts: The benefits of charitable remainder trusts. Proper use and abuse of familial limited partnerships. Valuation of buy-sell agreements under chapter 14 of the Internal Revenue Code