ACCRALAW offers a formal training program for its young lawyers. The Quality Circle, the committee tasked to implement the Firm’s training program, organizes monthly seminars on different topics of interest.
Last 21 September 2021, Partner Eric R. Recalde lectured on “The Legacy of PEACe Bonds.” He highlighted the terms of their issuance, the incidents leading to the dispute, and the impact of the Supreme Court decision not only in banking and financial transactions but also on the remedies of questioning tax issuances.
Mr. Recalde explained the process of issuing treasury bonds and the investment options of their holders. He also highlighted the distinction between: (a) coupon and zero-coupon debt instruments; (b) interests and trading gains when dealing with such instruments; (c) deposits and deposit substitutes; (d) public and private placements; and (e) with and without recourse assignment of debt instruments. He also discussed the discounting process, in particular the use of the fisher formula which highlights the relationship between nominal and effective interest rates under inflation, and how the trading price of zero-coupon debt instruments is determined.
He also explained when tax should be withheld: (a) when the debt instrument is interest bearing and when it is non-interest bearing; and (b) when the issuer is government and private enterprise.
Mr. Recalde also shared his insights the Court of Tax Appeals’ certiorari jurisdiction and how the PEACe Bonds Supreme Court en banc ruling changed the choice of court when questioning tax issuances.
Mr. Recalde is the Head of the Firm’s Tax Department.