IFLR is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

US tax court recharacterises preferred equity as debt in Hewlett Packard case

In Hewlett-Packard Co v Commissioner (TC Memo. 2012-135), the Tax Court recharacterised HP’s preferred equity as indebtedness and denied HP foreign tax credits and a capital loss on the exit transaction.

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login