Federal Income Taxation of Debt Instruments (2024)

David C. Garlock is a partner in the National Tax Department of Ernst & Young in Washington, D.C., where he has practiced since 1995. He is an expert in the taxation of financial products, including debt instruments and derivatives and, while serving as an attorney in the Treasury Department's Office of Tax Policy from 1982 to 1986, was the principal author of the 1986 proposed regulations relating to original issue discount. Mr. Garlock was an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center from 1989 to 1990 and has lectured extensively at continuing professional education programs in his areas of expertise. He is a past chair of the ABA Tax Section Committee on Financial Transactions. Mr. Garlock graduated cum laude from Harvard Law School in 1979 and magna cum laude in Mathematics from Harvard College in 1975.

Matthew S. Blum is a principal in the National Tax Department of Ernst & Young LLP in Boston, specializing in international tax and the taxation of financial products. Previously, he worked in the Washington, D.C. office of Cadwalader, Wickersham & Taft. His publications include U.S. Proposed Withholding Rules Changes, and International Tax Review 35 (1996). He is a graduate of Harvard College and received his J.D. from Harvard Law School in 1986.

Michael K. Yaghmour is a principal in the National Tax Department of Ernst & Young LLP in the Washington, D.C. office, specializing in the taxation of financial instruments and products. Prior to joining Ernst & Young, he was a director in PwC’s National Tax Services group in Washington, D.C. Prior to that, he also served as an associate general counsel at Fannie Mae and as a tax associate at Dewey Ballantine. Mr. Yaghmour speaks frequently at tax industry meetings on financial transactions and has authored several articles on the subject. He received his B.S. in Business Administration and Accounting from the University of Kansas in 1998 and his J.D. magna cum laude from Harvard Law School in 2001. He is admitted to the Bar in the District of Columbia and Oklahoma.

Richard G. Larkins is a partner in the National Tax Department of Ernst & Young LLP in the Washington, D.C. office, specializing in the taxation of financial instruments and products. Prior to joining Ernst & Young, Mr. Larkins was a principal in the Office of Federal Tax Services of Arthur Andersen LLP in Washington, D.C. Mr. Larkins has also worked as a Special Assistant to the Assistant Attorney General in the Tax Division of the U.S. Department of Justice and as an Attorney-Advisor in the IRS Chief Counsel's office. Mr. Larkins is a frequent speaker at tax conferences. He is a graduate of the University of Washington and received his J.D. from the Northwestern University School of Law. In addition to being admitted to the Bar in Illinois and the District of Columbia, Mr. Larkins is a certified public accountant.

Tyler L. Arbogast is a senior manager in the National Tax Department of Ernst & Young LLP in Washington D.C., specializing in the taxation of financial instruments and products. He is a co-author of an article entitled, LTR 201504004: IRS Offers Welcome Relief on Issue of Whether an Interest Is in Registered Form, 12 J. Tax’n Financial Products 39 (2015). He received his B.B.A. with special distinction from the University of Oklahoma in 2006 and his J.D. from Boston College Law School in 2009.