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Hybrid financial instruments: Classifying hybrid instruments under the debt/equity rules and related issues paper


This paper covers:

  • debt/equity in context
  • debt/equity outline
  • ENCO and options to convert to equity
  • equity credit features and ratings agency requirements
  • presentation in accounts
  • are returns deductible or frankable?
  • withholding tax implications
  • rollover relief on conversion.

Author profiles:

Author Photo - Cameron RIDER
Cameron RIDER
Cameron practices in corporate and international tax at Allens Arthur Robinson. Cameron’s practice currently encompasses corporate restructures and acquisitions (including in the mining sector), consolidation, taxation of financial arrangements and foreign currency transactions, taxation of intellectual property, and international transfer pricing. Cameron has returned as a Tax Partner at Allens Arthur Robinson after a period as Professor of Taxation Law at the University of Melbourne.
Current at 9 February 2009
Click here to expand/collapse more articles by Cameron RIDER.
Martin FRY
Current at 05 November 2013 Click here to expand/collapse more articles by Martin FRY.


This was presented at 48th Victorian State Convention .

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Individual sessions

Managing trust losses

Author(s):  Meagan O'CONNOR,  Rob JEREMIAH

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Division 7A the 'sleeping giant'

Author(s):  David STAVROPOULOS

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Bamford v Federal Commissioner of Taxation

Author(s):  Terry MURPHY

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Trusts and distribution resolutions in the light of Bamford

Author(s):  Nabil (Bill) F. OROW

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Inbound investment emerging issues

Author(s):  Vik KHANNA

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