Hedging Your Bets – Taxation of Financial Instruments and Transactions in Uncertain Times


Marcus S. Shore, Vice-Chair, TEI’s Federal Tax Committee, Dominion Energy Services, Inc.


  • Yoram Keinan, Kostelanetz & Fink, LLP
  • Jonathan R. Zelnik,  KPMG LLP

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.

Location: Date: March 25, 2021 Time: 11:30 am - 12:45 pm