Tax Law 101
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The Concept of Income
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Deductions
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Capital Gains and Losses
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International Tax Issues
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Anti-Avoidance Doctrines
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“Classic Tax Strategies”
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Issue Spotting Exercise: the Equity Forward Buyback case
The Story of SPAMS – Creation v.Evolution
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The Zero Coupon Bond
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Alternative Tax Regimes
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Original Issue Discount Regulations
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Bond and Preferred Stripping
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Money-market Fund Stripping
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Equity Buybacks and Their Tax Treatment
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The Genius of SPAMS
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Dealing with the Accountants
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Dealing with the Anti-Avoidance Tests
Opportunities with Derivatives and Structured Securities
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Characterization: Ordinary v. Capital
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Timing: Short-term v. Long-term
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Timing: Deferral Transactions
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Monetization Structures
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Timing: Accelerating Income to Cover Operating Losses
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Timing: Creating Capital Gain to Offset Capital Loss
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Source: Shifting Income Across Geographies
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Arbitraging the Carry
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Early Debt-Equity Hybrids
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Criteria Affecting the Debt-Equity Question
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Case Study in Security Design: The Unbundled Stock Units
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The Pinnacle – MIPS & TOPrS
Second Generation Tax Shelters
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Increasing the Interest Deduction with Kiwis
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Tax Sparing Treaties
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Do-It Yourself Tax Sparing
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Squeezing the FTC
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Basis Shifting Transactions
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Liquidating REIT and the Exclusion of Income
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Fast-Pay Stock and the Deduction of Principal
Reaction of the Revenue Services
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Shelter Registration Requirements
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Customer Disclosure Obligations
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Document Retention Obligations
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Penalties on Customer
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Excise Taxes on Promoter
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Penalties on Tax-indifferent Parties
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Denial of Certain Deductions
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GAAP/Tax Consistency Requirement