Taxation of Financial Instruments

This course addresses the U.S. federal income taxation of financial instruments from the perspective of issues that typically are encountered in a transactional tax practice at a law firm. The course first addresses the characterization of various financial instruments and derivatives for tax purposes and then addresses specific issues that arise with respect to each type of instrument. Issues are discussed in connection with indebtedness (including convertible debt, variable rate debt and contingent payment debt), equity (including common and preferred stock), notional principal contracts (e.g., swaps), options, forward contracts and credit derivatives. The applicable rules and issues are presented through a combination of lectures and in-class problem solving, with the instructor introducing practical examples of financial instruments encountered in his practice, whenever possible.
Credits: 2

Type: LEC