The Resource Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes

Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes

Label
Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes
Title
Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes
Creator
Subject
Language
eng
Summary
The tax treatment of optional convertible notes in New Zealand has recently come under scrutiny. This is partly due to the arbitrage that is made possible by the differing tax treatment of optional convertible notes in various jurisdictions. For example, New Zealand uses a bifurcation approach, whereas Australia uses a blanket categorisation approach in determining how an optional convertible note should be taxed. The former tax treatment of optional convertible notes gave rise to arbitrage possibilities. An argument is made for the legitimacy of such arbitrage under the former optional convertible note regime and the inability of the Commissioner to counteract such arrangements on a general anti-avoidance basis. The tax treatment of optional convertible notes in the United States, Australia and the United Kingdom is also examined, with a view to determining which method of taxing optional convertible notes is preferable
Citation source
In: New Zealand journal of taxation law and policy. - Wellington. - Vol. 17 (2011),
http://library.link/vocab/creatorName
Khoo, J
Language note
English
http://library.link/vocab/subjectName
  • optional convertible note
  • debt
  • tax arbitrage
  • GAAR
Label
Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes
Instantiates
Publication
Label
Line in the sand of the debt/derivative desert : the tax treatment of optional convertible notes
Publication

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