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Hybrid financial instruments: Classifying hybrid instruments under the debt/equity rules and related issues paper

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Published on 09 Oct 09 by VICTORIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • debt/equity in context
  • debt/equity outline
  • ENCO and options to convert to equity
  • equity credit features and ratings agency requirements
  • presentation in accounts
  • are returns deductible or frankable?
  • withholding tax implications
  • rollover relief on conversion.

Author profiles

Cameron Rider
Photo of author, Cameron RIDER Cameron Rider, FTI, is a Special Counsel at Greenwoods & Herbert Smith Freehills practising in corporate and international tax. He was a professor, and still teaches, at the Law School at the University of Melbourne. - Current at 05 May 2018
Click here to expand/collapse more articles by Cameron RIDER.
Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. Martin represented the taxpayer in Shell Energy v Commissioner of Taxation before the Federal Court, Full Federal Court and High Court. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. Martin has extensive experience in contentious matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 28 September 2022
Click here to expand/collapse more articles by Martin FRY.

 

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