The Japanese Ministry for Economics and Industry (keizai sangyousho/経済産業省) has sponsored a private research group (the ‘DES Research Group’) to look at the taxation of debt equity swaps (DES). One issue which they focus on is the uncertainty around the valuations used in the transactions concerned.
The DES Research Group published their report in January. Below are notes on the report written by the author of this post. The report which includes a useful summary of the history of tax reform in the area and the group’s proposals. Future postings will look in more detail at the taxation of DES and other corporate reconstruction transactions. Read More