Start date and time
July 25, 2013 2:00 PM
End date and time
July 25, 2013 3:00 PM
(GMT-05:00) Eastern Time (US & Canada)
Contact Dbriefs Registration options
Event registration is closed. Payment Information
There is no cost to attend Dbriefs webcasts.
Host: Jim Brock, Partner - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes
An advance of cash from a shareholder to its corporation or subsidiary can either be indebtedness, which is tax favored, or equity. The question of whether an instrument is debt or equity is often a close call, sometimes involving numerous judicial and governmental authorities. We'll discuss:
General factors that courts consider in determining debt-equity – the Mixon factors and Notice 94-47.
Evidence to demonstrate the debtor's ability to repay.
Whether the loan must be commercially reasonable.
How Section 385(c) applies to the debt-equity analysis.
Understand the law and leading practices for confirming that your interest deductions meet the more likely than not standard.
Please note: CPE Credit is not available for viewing archived programs.
Subscribe to Dbriefs
Update My Dbriefs Profile
Event registration is closed.