Press of K&L Gates LLP Original Title: IRS Issues Private Letter Ruling on Debt/Equity Treatment Under Liberalized Ruling Procedures Introduction. The classification of a financial instrument as debt or equity is a fundamental, recurring question under the Internal Revenue Code of 1986, as amended (the "Code").?On By Thomas F. 111.).

Moves to amend the US's Dodd-Frank Wall Street Reform and Consumer Protection Act - the voluminous and wide-ranging response to the financial crisis that passed into law last summer - were widely reported in the press this week, and they caught the attention of the European private equity industry. By SJ Berwin LLP and Goodwin Procter LLP.