Distinguishing Equity From Debt in Related Party Contexts

, New York Law Journal


In his Taxation column, David E. Kahen discusses 'Bell v. Commissioner', writing: Overall, the results reached in 'Bell' are not surprising in light of the case law. This case is a reminder of the courts' willingness to reclassify transactions—including reclassification as stock of obligations intended to be debt for tax purposes—even without express authorization by statute or regulation, and to plan in a manner that avoids or minimizes such risks.

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