The Tax Court recently issued its opinion in PepsiCo Puerto Rico, Inc. et al. v. Commissioner, T.C. Memo 2012-269, another in a recent spate of cases in which the IRS has argued, contrary to classic debt - equity wrangling, that an arrangement should be treated as debt rather than equity.
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RegisterTax Court upholds equity treatment of hybrid instrument in PepsiCo Puerto Rico
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USA
December 20 2012
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Nadia Martel
Senior Legal Counsel
C2MI
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