Two senior lawyers from Mayer Brown provided a digestible version of the US federal income tax classification and treatment of structured notes during the SRP Americas 2024 Conference in New Orleans.
The US tax law does not have clear-cut rules for structured notes, according to Remmelt Reigersman (pictured) , partner, Northern California, Mayer Brown. The tax law has clear cut rules about the taxation of debt, or the taxation of forward contracts, or options or swaps, but structured notes don't really fall into any one of those categories - Remmelt Reigersman “The tax law has clear cut rules about the taxation of debt, or the taxation of forward contracts, or options or swap
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