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Riassunto: Federal Income Taxation of Debt Instruments is the definitive reference for the many complicated issues involved with debt instruments. This comprehensive treatise contains clear interpretations of the basic rules governing original issue discount and imputed interest and detailed coverage of many specialized topics. In addition to complete coverage of the final OID regulations, the book covers virtually every aspect of the taxation of debt instruments and many related areas. CONTENTS: - Basic Concepts - Determining Total Original Issue Discount - Imputed Interest on Debt Issued for Property - Below-Market and Intercompany Loans - Current Inclusion and Deduction of OID - Accounting for Interest - Short-term Obligations - Variable Rate Debt Instruments - Contingent Debt Instruments and Integration - OID: Additional Special Topics - Market Discount - Bond Premium - Sales, Exchanges, Recapitalizations and Redemptions - Debt Modifications - Cancellation of Debt - Coupon Stripping - Information Reporting and Withholding - International Issues
L'autore: David C. Garlock is a partner in the National Tax Department of Ernst & Young LLP in the Washington, D.C. office, specializing in the taxation of financial instruments and products. From 1986 to 1995, he was a tax partner in the Washington, D.C. office of Dewey Ballantine. Mr. Garlock was an attorney in the U.S. Department of Treasury s Office of Tax Policy from 1982 through 1986 and served as Associate Tax Legislative Counsel. He was the principal author of the 1986 proposed OID regulations and was also an active participant in the development of the 1986 legislation relating to mortgage-backed securities. Mr. Garlock is the author of numerous articles on the taxation of financial products and is an Adjunct Professor of Law at the Georgetown University Law Center. He received is a graduate of Harvard College and recieved his J.D. from Harvard Law School in 1979. Matthew S. Blum is a principal in the National Tax Department of Ernst & Young LLP in Boston, specializing in international tax and the taxation of financial products. Previously, he worked in the Washington, D.C. office of Cadwalader, Wickersham & Taft. His publications include U.S. Proposed Withholding Rules Changes, 7 International Tax Review 35 (1996). He is a graduate of Harvard College and received his J.D. from Harvard Law School in 1986. Dr. Kyle H. Klein is a principal in the National Tax Department of Ernst & Young LLP in Washington, D.C., specializing in the taxation of financial institutions and financial products. Prior to joining Ernst & Young LLP, she was Tax Accounting Fellow at the Federal Home Loan Bank Board (now the Office of Thrift Supervision) and worked in the San Francisco office of Deloitte, Haskins & Sells. Dr. Klein is a frequent speaker at industry conferences, is a member of the AICPA Financial Institutions Tax Committee, and writes the quarterly tax update for Bank Accounting and Finance. She is a graduate of Tulane University and received her M.B.A. and Ph.D. from the University of Arkansas. Richard G. Larkins is a partner in the National Tax Department of Ernst & Young LLP in the Washington, D.C. office, specializing in the taxation of financial instruments and products. Prior to joining Ernst & Young, Mr. Larkins was a principal in the Office of Federal Tax Services of Arthur Andersen LLP in Washington, D.C. Mr. Larkins has also worked as a Special Assistant to the Assistant Attorney General in the Tax Division of the U.S. Department of Justice and as an Attorney-Advisor in the IRS Chief Counsel's office. Mr. Larkins is a frequent speaker at tax conferences. He is a graduate of the University of Washington and received his J.D. from the Northwestern University School of Law. In addition to being admitted to the Bar in Illinois and the District of Columbia, Mr. Larkins is a certified public accountant. Alan B. Munro is a partner in the National Tax Department of Ernst & Young LLP in the Washington, D.C. office, specializing in the taxation of financial instruments and asset managers. Immediately prior to joining Ernst & Young, Mr. Munro was a partner in the Office of Federal Tax Services of Arthur Andersen LLP in Washington, D.C. Prior to that, he spent six years (the last two years as a Branch Chief) in the Financial Institutions & Products division of Chief Counsel, Internal Revenue Service. Mr. Munro was a principal author of the final regulations on notional principal contracts and on conversion transactions. Previously, he worked in a number of New York-based law firms. Mr. Munro is a graduate from the University of Virginia and recieved his J.D. magna cum laude from Washington & Lee University and his LL.M. in Taxation from New York University.
Condizione libro: Used
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