In Pepsico Puerto Rico, Inc v Commissioner, the US Tax Court found that PepsiCo's 'advance agreements' between Pepsico Puerto Rico (a Delaware corporation) and a Netherlands affiliate were equity rather than debt for federal income tax purposes. This, in turn, permitted PepsiCo to treat payments on the advance agreements as non-taxable returns of capital rather than interest payments for the taxable years in question.
January 24 2013