The article discusses a recent
proliferation of the hybrid financial instruments
and strives to aid the tax practitioner in
understanding the analytical framework underlying
such instruments, which often raise heightened
attention of the revenue authorities in various
jurisdictions and are sometimes thought to be
problematic from the tax compliance point of view.
The article reaches a conclusion that the current
legal framework does not prohibit hybrid instruments
per se and argues that most of such transactions are
not abusive.
