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Cross-Border Convertible Debt

Fenwick & West LLP

Tax Alert: IRS Untangles Section 163(L) in Cross-Border Hybrid Financing Transaction

Fenwick & West LLP on

“In terrorem” or anti-abuse provisions often receive a lack of judicial and administrative interpretation. Section 163(l) of the Code, enacted in 1997, is no exception, so that even now certain fundamental questions relating...more

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