Use of Contingent Debt Instruments in Cross Border Transactions
International Fiscal Association
Speaking Engagement
October 2, 2023
Daniel Martinez participates in a panel titled Use of Contingent Debt Instruments in Cross Border Transactions at the USA Branch of the International Fiscal Association's YIN Webinar. Panelists discuss the tax issues related to the use of contingent debt instruments in cross-border transactions, including, exploring the different definitions of contingent debt, issues in connection with the portfolio interest exception, FIRPTA considerations, and the treatment of contingent debt under U.S. tax treaties.
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