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In view of the confused state of the law, how should a tax advisor plan the capital structure of a corporation to avoid the risk

In view of the confused state of the law, how should a tax advisor plan the capital structure of a corporation to avoid the risk of reclassification of debt as equity. From the standpoint of the tax advisor, is the vagueness of the law in this area preferable to more detailed "bright line" rules in the IRC or the regulations and which approach is preferable as a matter of policy?

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