Moderator:
Marcus S. Shore, Vice-Chair, TEI’s Federal Tax Committee, Dominion Energy Services, Inc.
Speakers:
Session Description:
This session will provide an overview of the general rules relating to tax hedging and explore current issues in financial instruments that are arising during these uncertain times.
Learning Objectives:
In this session, panelists will discuss: (1) the general rules of tax hedging and the treatment of inadvertent errors in identification, (2) the treatment of call spread convertibles and integration elections under Reg. §1.1275-6, (3) the definition of interest under the final regulations of §163(j), (4) the tax character of break-up/ termination fees, (5) tax issues for holders and issuers of destressed debt, (6) tax issues arising from losses on debt instruments, and (7) the transition rules from LIBOR to SOFR.