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Tax Court upholds equity treatment of hybrid instrument in PepsiCo Puerto Rico

Baker McKenzie

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USA December 20 2012

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.

Content is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee similar outcomes. For more information, please visit: www.bakermckenzie.com/en/client-resource-disclaimer.

Baker McKenzie - Eric M. McLimore and Samuel P. Grilli

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Filed under

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