ABA Virtual 2023 Fall Tax Meeting

October 20, 2023

Event Overview Tab


Cleary Gottlieb partner Meyer Fedida participated in the ABA Virtual 2023 Fall Tax Meeting.

Meyer spoke on the panel, “Big Bad Debt: The Application of Sections 165 and 166 to Intercompany Financings,” which addressed the availability of section 165 worthless security and section 166 bad debt deductions for inter-affiliate financings. Among other topics, the panel also addressed debt/equity issues, the definition of “security” under section 165(g)(2)(C), the application of the rules for securities in affiliated corporations under section 165(g)(3), the requirements for partial and wholly worthless debt deductions under section 166, the applicability of TEFRA, cancellation of indebtedness income, and best practices for documenting intercompany financing arrangements.

For more information about the event, visit the website.