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Taxation as a Driver for Designing Hybrid Securities

Changes in 2001 to the tax laws for Hybrid securities occurred at the same time as proposed accounting, regulatory and ratings agency changes for those types of securities. The tax law changes appear to have had their intended effect on the targeted Hybrid securities, Income Securities, but it also appears that the design of Hybrid securities following those changes owes more to the accounting, regulatory and other changes that were occurring than to the changes in the tax laws.