Tax Controversy & Transfer Pricing
Analysis of Capital Structure & Debt-Equity Disputes

Investment characterization often affects the tax treatment of financial securities. Brattle has been retained to opine on various issues subsumed by this category, such as:

  • Whether funds transferred from one party to another should be characterized as debt or equity for tax purposes;
  • Appropriate intercompany leverage ratios;
  • The impact of implicit and explicit intercompany guarantees; and
  • Characterization of capital and financing leases.