Escuela de Derecho

The purpose of this seminar is to analyze the main principles that govern the taxation of important equity and debt financing products.  First, the analysis will focus on the distinction between debt and equity.  Second, basic equity and debt structures will be studied, such as ordinary shares, preferred shares, irrevocable contributions, loans (including cases in which double taxation treaties apply), negotiable obligations (either publicly or privately offered). The analysis will also focus on "hybrid" instruments (such as convertible negotiable obligations) and typical financing and securitization structures, such as private or public financial trusts, foreign trusts, mutual funds, leasing, etc. Finally, derivatives (options, swaps, forwards, etc) will be covered. The analysis of each financial structure or product will also address tax policy issues.