Robert Feldgarden
Subscribe to Robert Feldgarden's PostsRobert Feldgarden, PC, provides legal counsel on a variety of federal income tax matters, including the design and analysis of novel financial instruments intended to achieve favorable income tax consequences, the taxation of foreign currency transactions, the taxation of foreign operations of US-based multinational companies, the taxation of domestic operations of foreign-based multinational companies and stock options, and other executive compensation vehicles.
Scott Singer Informs on the Effect of Loans to Financially Troubled Subsidiary in a Debt-Equity Analysis
By Robert Feldgarden on Aug 26, 2016
Posted In Court Procedure Matters, Transfer Pricing Resource, Uncategorized
One often overlooked debt-equity issue is presented by continuing transfers to a subsidiary that is reasonably creditworthy at the inception but subsequently encounters difficulties, in spite of which (or maybe because of which) and continues to receive advances from the common parent or one of its finance subsidiaries. The issue is whether the subsequent difficulties...
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