Federal Income Taxation of Debt Instruments (2026)

David C. Garlock was a principal in the National Tax Department of Ernst & Young LLP, specializing in the taxation of financial instruments and products until his retirement in June 2017. From 1986 to 1995, he was a tax partner in the Washington, D.C. office of Dewey Ballantine. Mr. Garlock was an attorney in the U.S. Department of the Treasury's Office of Tax Policy from October 1982 through July 1986 and served as Associate Tax Legislative Counsel for the last two years of his tenure there. He was the principal author of the 1986 proposed OID regulations and was also an active participant in the development of the 1986 legislation relating to mortgage-backed securities. Mr. Garlock is the author of numerous articles on the taxation of financial products and was an Adjunct Professor of Law at the Georgetown Law Center and the University of Michigan Law School. He received his A.B. magna cum laude from Harvard College in 1975 and his J.D. cum laude from Harvard Law School in 1979. Mr. Garlock was admitted to the Bar in New York and the District of Columbia (both now inactive). He is also the author of The Greatest Brainteasers of All Time, available from the author.

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 managing director in the U.S. National Tax Department of Andersen Tax LLC in Washington, D.C. Mr. Larkins was previously 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 for nearly 19 years until his retirement in December 2020. Immediately 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 received his B.A. in Accounting from the University of Washington in 1984 and his J.D. from the Northwestern University Pritzker School of Law in 1990. Mr. Larkins is admitted to the Bar in Illinois (inactive) and the District of Columbia.

Tyler L. Arbogast is a principal in the National Tax Department of Ernst & Young LLP, specializing in the taxation of financial instruments and products. He is the former chair of the Committee on Financial Institutions & Products for the American Bar Association. Mr. Arbogast has spoken on multiple occasions at tax industry meetings on financial products and has authored or contributed to several articles and comment letters on the subject. 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. He is admitted to the Bar in the District of Columbia and Massachusetts.