Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.
The global pandemic has had an unprecedented impact on businesses. For some the pandemic has stressed their financial position such that a restructuring is necessary. This may involve reducing debt liabilities through releases equity injections to pay down debt or easing the debt burden through changes to terms of borrowings.
This article is the first in a series discussing tax issues of restructuring corporate debt. It discusses debt releases and debt for equity swaps. Deemed releases and modifications shall be covered in later articles. All statutory references are to CTA 2009 unless otherwise stated.
Which provisions apply to taxing a debt?
Where a debt arises from the lending of money then it is a loan relationship. Where an instrument has been issued to represent the...
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Companies emerging from the pandemic may undertake a debt restructuring. Paul Pritchard (FTI Consulting) discusses current tax issues with debt releases.
The global pandemic has had an unprecedented impact on businesses. For some the pandemic has stressed their financial position such that a restructuring is necessary. This may involve reducing debt liabilities through releases equity injections to pay down debt or easing the debt burden through changes to terms of borrowings.
This article is the first in a series discussing tax issues of restructuring corporate debt. It discusses debt releases and debt for equity swaps. Deemed releases and modifications shall be covered in later articles. All statutory references are to CTA 2009 unless otherwise stated.
Which provisions apply to taxing a debt?
Where a debt arises from the lending of money then it is a loan relationship. Where an instrument has been issued to represent the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
