shopping_cart

Your shopping cart is empty

The concept of ENCO

Member Price: $35.00
Non Member Price: $45.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 01 Aug 08 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The concept of “effectively non-contingent obligation” (ENCO) is central to the application of the debt/equity rules. It is a difficult concept, not the least because of the poor wording of the legislation but also the lack of case law guidance. After examining the words, the structure and the history of the ENCO concept, this article proposes a conceptual framework to comprehend this concept in a bid to solicit further debate in this area.

Author profile

Kai Zhang FTI
Kai is a Tax Consultant with Greenwoods & Freehills. - Current at 01 June 2009
Click here to expand/collapse more articles by Kai ZHANG.

 

Copyright Statement