IRS Eyes Taxes in Debt - Equity Swaps
According to Chadbourne & Park, LLP, the Internal Revenue Service (IRS) is auditing U.S. companies that bought shares in foreign utilities in recent privatizations to determine whether they should have paid U.S. taxes.
All of the transactions involve debt-equity swaps, which can take many forms. For example, a U.S. company interested in buying shares in a foreign utility first goes into the market to buy bonds of the foreign government.